United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Washington DC 20460
OSWER Directive 9345.0-01
January 1988
Superfund
oEPA
Preliminary Assessment
Guidance
Fiscal Year 1988
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PRELIMINARY ASSESSMENT GUIDANCE
FOR FISCAL YEAR 1988
OSWER DIRECTIVE 9345.0-01
U.S. Environmental Protection Agency
Office of Emergency and Remedial Response
Washington, O.C.
January 1988
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OSWER DIRECTIVE 9345.0-01
NOTICE
The information in this document has been funded
wholly or in part, by the United States
Environmental Protection Agency under Contract
No. 68-01-7347 to Ecology and Environment, Inc.
It has been subject to the Agency's peer and
administrative review and has been approved for
publication as an EPA document.
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OSWER DIRECTIVE 9345.0-01
EXECUTIVE SUMMARY
The purpose of this guidance is to provide Regions, States,
Field Investigation Teams (FITs), and other Federal agencies
with direction for conducting new preliminary assessments (PAs)
and reassessing existing PAs during FY 88. This guidance is
intended to standardize PA scope, products, and decisions, and
to foster improved PA quality. It will be in effect until the
Hazard Ranking System (HRS) is revised and is consistent with
the anticipated direction of the revised National Contingency
Plan (NCP). This guidance also provides Regions with direction
for handling PA petitions from the public in anticipation of the
proposed revision of the NCP dealing with such petitions and
briefly touches on preliminary procedures for the Environmental
Priorities Initiative (EPI).
The guidance is organized to provide direction on three
distinct but related preliminary assessment topics: conducting
new PAs; reassessing existing PAs; and, handling public
petitions for PAs. The guidance summarizes pertinent statutory
and regulatory provisions, including the requirements of the
Superfund Amendments and Reauthorization Act of 1986 (SARA).
The sections of the guidance on new PAs also explain and
illustrate the increased number of hours for conducting PAs; the
steps that must be undertaken to complete PAs; the kind and
quality of information required; the content and preparation of
the PA report; and the method for entry of PA data in the
expanded Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS) PA tracking system.
The PA reassessment section of the guidance describes the
procedures to be used in reviewing existing PAs for which Sis
are not yet underway. PA reassessments will give the Regional
staff an opportunity to change the priority of a site for site
inspection, if appropriate.
The final guidance section provides direction for handling
PA petitions. Specific procedures for PA petitions are
incorporated in Appendix D which describes the information that
PA petitions must include to enable Regional staff to determine
whether a PA should be performed. The appendix also includes
the criteria to be used to make the determination and explains
how the criteria should be interpreted. It concludes with a
sample PA petition format; model letters for acknowledging and
responding to PA petitions; a model cover letter to send with
the completed PA report to successful petitioners; and
information on CERCLIS tracking of PA petitions.
Other appendices provide a list of potential sources for
information for PAs; a data checklist to facilitate information
collection; a copy of EPA form 2070-12 which may be used for PA
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OSWER DIRECTIVE 9345.0-01
reports; procedures for handling PA petitions from the pub
and criteria for removal response.
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OSWER DIRECTIVE 9345.0-01
TABLE OF CONTENTS"
Page
EXECUTIVE SUMMARY ill
r
1.0. INTRODUCTION 1
1.1 Statutory and Regulatory Requirements 2
1.2 Definition of a PA 3
1.3 PA Goals 4
2.0 GUIDANCE FOR CONDUCTING NEW PAS 6
2 .1 Candidate Sites . . . . 6
2.2 PA Scope and Hours 6
2.3 Elements of a PA 7
2.3.1 Review of Existing Information 8
2.3.1.1 Review of Technical
Information Sources 8
2.3.1.2 Information on Site History/
Regulatory Status 11
2.3.2 Site Reconnaissance 12
2.3.2.1 Off-Site Reconnaissance 12
2.3.2.2 On-Site Record Search
and Interviews 13
2.3.2.3 On-Site Reconnaissance 13
2.3.3 Development of Preliminary and
Projected HRS Scores
2.3.4 Application of Qualitative Criteria
2.3.5 Priorities for Site Inspections ....
2.3.6 Report Content and Preparation
.2.3.7 Documentation .
2.3.8 CERCLIS Tracking
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OSWER DIRECTIVE 9345.0-01
TABLE OF CONTENTS (continued)
3.0 GUIDANCE FOR REASSESSING EXISTING PAS
4.0 GUIDANCE FOR HANDLING PUBLIC PA PETITIONS
4.1 Introduction and Background
4.2 Statutory Requirements ,
5.0 CONTACTS FOR FURTHER INFORMATION ,
APPENDIX A:
APPENDIX B:
APPENDIX C:
APPENDIX D:
INFORMATION SOURCES
DATA CHECKLIST
EPA FORM 2070-12
CRITERIA AND PROCEDURES FOR HANDLING PA
PETITIONS
APPENDIX E: CRITERIA FOR REMOVAL RESPONSE
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OSWER DIRECTIVE 9345.0-01
1.0 INTRODUCTION
EPA has developed a.deliberate and structured process to
determine what, if any, cleanup actions should be taken at
uncontrolled hazardous waste sites. The entire site evaluation
process consists of two major phases. The first phase leads to
the proposing of sites for the National Priorities List (NPL).
This pre-remedial phase involves four major activities —
discovery, PA, site inspection (SI), and HRS evaluation. The
second or remedial planning phase involves evaluating a site in
sufficient detail to identify the magnitude and extent of
contamination, the populations affected, and the most
cost-effective alternative for correcting problems at the site.
This second phase consists of two activities — a remedial
investigation (RI) and a feasibility study (FS). These two
phases result in a record of decision (ROD), followed by
remedial design (RD) and remedial action (RA).
The goals of the pre-remedial phase apply to both the PA
and the SI and involve:
1) gaining an understanding of the nature
and degree of the threat posed by a
site;
2) determining the likelihood of an HRS
score of 28.5, or higher, and
collecting data to correctly score the
site using the HRS;* and
3) identifying sites that may require
immediate response (i.e., removal
action).
EPA Regions can act as the lead agency for Comprehensive
Environmental Response, Compensation, and Liability Act of 1980,
as amended, (CERCLA) PAs or can authorize States to perform PAs
through cooperative agreements. When a State is the lead agency
for a PA, the State will make a recommendation upon which the
* In making this determination, individual Regions may use
a threshold score lower than the HRS cut-off to ensure that
marginal sites are not eliminated from CERCLA remedial
consideration prematurely. Removal action is never dependent
upon a site scoring at or above the HRS cut-off.
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OSWER DIRECTIVE 9345.0-01
Region will base its decision about whether future remedia
response under CERCLA is required. PAs at Federal facilit
will be conducted by the appropriate Federal agency.
The revisions to the HRS have not been proposed as 'of
January 1988. Thus, this guidance is interim and will be
revised and finalized once the HRS revisions are effective
Some of the specific guidance on the technical information
collected during the PA, particularly those items in Attac
B (the PA Checklist), are subject to change. These checkl
items are based on the current HRS and draft revised HRS
factors, and some of the items will likely change in respo
comments on the proposed revisions to the HRS.
1.1 Statutory and Regulatory Requirements
The Superfund Amendments and Reauthorization Act of 1'
(SARA), enacted on October 17, 1986, established several
requirements concerning the pre-remedial process. For PAs
particular:
o New CERCLA section 116(a) requires that, to
maximum extent practicable, PAs are to be
conducted by no later than January 1, 1988 <
sites contained in CERCLIS as of the date o
enactment. Included within each of these P/
should be a statement as to whether an SI i:
necessary and by whom it should be carried <
o For all facilities contained in CERCLIS as -
date of SARA enactment, new CERCLA section
requires an HRS evaluation (if warranted).
o For all facilities entered into CERCLIS aft
SARA enactment, new CERCLA section 116(b)
requires HRS evaluation (if warranted) with
four years of the facility's CERCLIS entry.
(This means the PA should be completed prom
so that HRS evaluation can be completed wit
four years.)
«.
o New CERCLA section 105(d) requires that a F
completed within 12 months of the receipt o
complete PA petition concerning a release,,
EPA determines that the PA is not appropria
This provision also requires prompt HRS
evaluation, where warranted.
o New CERCLA section 120 discusses Federal
facilities and indicates that for any sites
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OSW2R DIRECTIVE 9345.0-01
included in the new Federal facilities docket,
EPA must ensure that PAs are completed by April;
17, 1988. HRS packages are to be completed,
where warranted, such that listing on the NPL
will occur by April 17, 1989. (Under Executive
Order No. 12580, January 23, 1987, the governing
Federal agency is responsible for performing PAs
at Federal facilities. • EPA and the States are
not authorized to perform them.)
These provisions have implications for pre-remedial
activities beyond the bare requirements they contain. First,
the Regions, States, and Federal agencies should make it a goal
to complete all PAs within one year of each site's entry into
CERCLIS. Maintaining this pace of PA completions will better
ensure that the four-year deadlines for performing HRS
evaluations will be met. Second, SARA acknowledges that some
sites in CERCLIS may not warrant HRS evaluation. This statutory
acknowledgement, coupled with resource constraints, underscores
the need to ensure that limited resources are expended on the
sites that warrant Sis. Therefore, it is important that a high
quality effort is undertaken to ensure that those sites that do
not require further evaluation are identified and screened out.
As a result, those sites that do require such an evaluation can
receive it promptly and in compliance with statutory deadlines.
1.2 Definition of a PA
A PA is an initial analysis of existing information to
determine if a release of hazardous substances may be serious
enough to require additional investigation or action. The PA is
the first phase in the process of determining whether a site is
releasing, or has the potential to release, hazardous
substances, pollutants, or contaminants into the environment and
whether it requires response action that is authorized by
CERCLA. During a PA the investigator compiles and evaluates
available information about a site and its surrounding
environment, including information on potential waste sources,
migration pathways, and receptors. The PA culminates in a brief
report with formal recommendations. While the PA does attempt
to establish whether the site has the potential to adversely
affect the environment, it is not intended to determine the
exact magnitude of the release, or whether the size of the
release is significant. These determinations are made, in a
simplified fashion, when the site is scored under the HRS after
completion of an SI and, more comprehensively, during the
subsequent remedial investigation.
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OSWER DIRECTIVE 9345.0-01
1.3 PA Goals
The PA has the following four specific goals:
o Eliminate sites where CERCIA remedial a&t:
not required. The first goal of the PA is
screen out those sites in the CERCLA wast<
inventory (the Comprehensive Environmental
Response, Compensation, and Liability Infc
System or "CERCLIS") that are ineligible 1
CERCLA remedial response, pose no threat t
public health or the environment, or where
further action under the remedial program
warranted. The amount of information that
available on a site when it is entered in
varies considerably. .The following are e>
of the kinds of situations where experienc
indicates no further CERCLA remedial actic
be required:
the site has no potential to score 21
higher on the current HRS; or
the site does not exist.
At other sites no CERCLA response action v
taken for legal, regulatory, or statutory
reasons, as follows:
no CERCLA-designated hazardous substc
pollutant or contaminant is involved;
the release involves naturally occur]
substances in their unaltered form fi
location where the substances are nat
found;
the release is from products which ai
of the structure of, and result in ej
within, residential buildings or bus-
community structures;
the release is into public or privat<
drinking water systems due to deteri<
of the system through ordinary use?
the release is the result of the nor;
application of fertilizer;
the release results in exposure to p
solely within a workplace;
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OSWER DIRECTIVE 9345.0-01
the release involves_ source, byproduct, or
special nuclear material from a nuclear
incident if such release is subject to the
financial protection requirements
established by the Nuclear Regulatory
Commission under section 170 of the Atomic
Energy Act of 1954, or source byproduct or
special nuclear material from any processing
site designated under section 102(a)(1) or
302(a) of the Uranium Mill Tailings
Radiation Control Act of 1978; or
the release involved is from natural or
synthetic petroleum or natural gas products.
If a determination can be made that CERCLA
remedial action is not required based on such
legal, statutory, regulatory, or policy reasons,
there is no reason to fulfill remaining PA goals.
The PA report should be prepared at this point
and should explain why such a determination was
made. For this reason, opportunities to
eliminate sites from further consideration should
always be evaluated early in a PA.
Identify sites that require emergency response.
CERCLA removal authority allows EPA to take
immediate action at a site regardless of whether
the site is on the NPL. The PA can determine if
the site, or a portion of it, may qualify for
removal action, thereby warranting referral to
the removal program. This allows clean-up
activities to proceed in advance of a
determination about whether the site qualifies
for the NPL. The PA should rigorously evaluate
the site to determine if it may merit removal
action. (Appendix E lists the criteria that EPA
uses in determining the appropriateness of
removal response.)
Compile information necessary to develop
preliminary and pro-iected HRS scores. If the
site may pose a threat that warrants remedial
action, the PA should collect data to develop
preliminary and proposed HRS scores. The
development of these scores is the Site Screening
Analysis (SSA) which will form the basis for
making a management decision on the priority of a
site for site inspection. The derivation of SSA
scores is discussed in Section 2.3.3 (p.13).
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OSWER DIRECTIVE 9345.0-01
o Set priorities for Sis. The fourth goal of t
PA is to set the priority of the site for an
Traditionally, more sites are referred for
further action than the available resources c
immediately accommodate. Thus, EPA must '
establish priorities for further investigatioi
Section 2.3.5 (p. 16) discusses this priority
setting approach.
2.0 GUIDANCE FOR CONDUCTING NEW PAs
2.1 Candidate Sites
This guidance applies to all PAs that will be conducted
sites included in CERCLIS, regardless of the date of entry i
CERCLIS, who performs the PA (EPA, States, or Federal agenci
or the method of entry into CERCLIS (conventional discovery
notification or PA petition). This guidance also applies toi
RCRA sites that may be entered in CERCLIS for CERCLA attenti
under the Environmental Priorities Initiative (EPI).
In the interest of public health and the environment, E
has decided that CERCLA resources will be used to evaluate R
storage and treatment facilities, and closed or closing RCRA
facilities (including closed or closing land disposal
facilities). Active incinerators and active land disposal
facilities will not be evaluated. During FY 88, the RCRA
program will prioritize eligible RCRA sites for entry into
CERCLIS. PAs will be conducted for these sites in the same
manner as non-RCRA sites. RCRA sites will be evaluated and
prioritized for Sis based on the environmental conditions of
site. If a site is determined to warrant no remedial action
under CERCLA, EPA will terminate CERCLA remedial response ar
the site will be referred to RCRA for attention. (Guidance
governing EPI sites is being developed and will be issued ir
second quarter of FY 88.)
2.2 PA Scope and Hours
The scope of the PA must be sufficient to determine whe
further action is warranted, to collect the requisite data t
develop preliminary and projected HRS scores, document the c
adequately, substantiate the recommendation made in the PA
report, and prioritize the site for future action. Some sit
may require the collection of data for such additional piirpc
as addressing site-specific public concerns. Data collectic
for additional purposes, however, should be carefully evaluc
to ensure that it does not compromise the collection of the
necessary to meet the PA's primary goals. It may be possib:
defer gathering such additional data until the SI for which
funds and other resources are available.
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OSWER DIRECTIVE 9345.0-01
To enable lead agencies to make accurate and consistent
decisions supported by well-documented data, the time necessary
to conduct the PA described in this guidance will increase by
approximately 50 percent in FY 88, increasing the hours for an
average PA from 50 to 75. The increase in hours will
accommodate additional collection of data, off-site
reconnaissance, development of preliminary and projected HRS
scores, and report preparation and documentation. Seventy-five
hours is an average. EPA expects the number of hours required
to conduct a PA that will meet the goals and objectives
described in Section 1.3 (p.4) to vary in both directions. PAs
at some sites could take up to 100 hours to complete if the
effort is likely to be particularly productive and to
significantly strengthen the Agency determination regarding the
site. In other cases, fewer hours may suffice. The latter may
occur where a determination can be made that CERCLA remediation
is clearly not warranted. In this case, further effort to
collect HRS-type data is unnecessary and the only time required
will be that necessary to write up the PA report. PAs rarely
should exceed 100 hours.
2.3 Elements of a PA
The PA is a multi-step process consisting of:
(1) Review of existing information;
(2) Site reconnaissance;
(3) Development of preliminary and projected HRS
scores;
(4) Application of qualitative criteria;
(5) Prioritization for site inspection;
(6) Report preparation;
(7) Documentation; and
(8) CERCLIS tracking.
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OSWER DIRECTIVE 9345.0-01
2.3.1 Review of Existing Information
The first step in a PA is an examination of existing
information about the site. The site' information that ,sh
examined falls into two categories:
o Technical data to evaluate whether the ait
a threat; and
o Information on the regulatory history and
of the site to determine whether the site
subject to other Federal or State authorit
A thorough examination of these data need not occur
any point in the review process a definitive, documentabl
determination can be made that no further CERCLA remedial
is necessary at the particular site. Even in such cases,
however, preparation of a PA report documenting this find
necessary*
2.3.1.1 Review of Technical Information Source
The first information that should be examined during
is data that may be useful in evaluating the threat posed
site. (Appendix A identifies potential information sourc
The lead agency should consult only those sources likely
produce data required for the particular site, as outline
below.)
The data that should be reviewed routinely for each
fall into four categories:
o Site description and management practices
Detailed site map showing location, s
water supplies, sensitive environment
surrounding population;
Site status, i.e., whether the facilj
an ongoing operation or the site has
abandoned;
Nature and type of industrial process
were carried out on the site or at"
facilities that shipped waste to the
Facility location and description.in<
size, layout of existing disposal un.
other existing structures, and well
locations;
Operations history, including descri]
of activities and site ownership;
Land use, including use of and acces.
site and adjacent property;
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OSWER DIRECTIVE 9345.0-01
Aerial photographs documenting operations
over time; and
General location map illustrating geology,
land use, and critical habitats and
receptors within a 5-mile radius of the
site.
o Waste characteristics
~ Quantity; and
Toxicity.
o Dispersal pathways
Geology, hydrogeology, surface water
resources, air quality, and meteorology.
o Receptor populations and environments
Characteristics of the environmental
setting; and
Demography, including location and number of
actual and potential receptors.
Data in these categories are essential to develop an
understanding of the threat posed by site. Appendix B presents
a data checklist for gathering information in the categories
outlined above. The data checklist is organized so that the
lead agency can use the checklist data directly to develop
preliminary and projected HRS scores (as described in Section
2.3.3 (p.13)). The factors that have the most impact on HRS
scoring are capitalized and highlighted in bold type in the
checklist. The PA timeframes outlined in Section 2.2 (p.7)
should be used as a guide for determining the extent of
information review possible at an individual site.
In some cases, it will not be necessary to pursue answers
to certain of these questions. First, certain categories of
questions may not apply to a site. For example, at some sites
where no surface water exists within a wide radius of the site,
questions about potential surface water impacts may not need to
be considered. In this circumstance, the PA report should
indicate that surface water is not a viable route of exposure at
the site and why.
Second, the investigator may find that the time necessary
to respond to certain questions requires expanding the PA to
significantly more than 75 hours. As a rule of thumb, an
additional 25 hours to develop information may be excessive;
five additional hours may be a reasonable increase if the
information may make a significant difference in the assessment
of the site.
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OSWER DIRECTIVE 9345.0-01
Finally, for some sites, it may be difficult to respond
certain checklist questions with existing data and on-site
reconnaissance of the contaminated area would be needed to*
correctly answer the questions. In these cases, unless goin
on-site would make a significant difference in the final
disposition of the site, the investigator should not try to
collect the data first hand, but rely, at this point, on bes
judgment. On-site data should be collected only in the
exceptional circumstances described in Section 2.3.2.3 (p.13
The data collected must be sufficient in quality and de
to develop useful and meaningful preliminary and projected Hi
scores and to substantiate the resulting recommendations.
Previous PAs have sometimes overlooked available data or fai:
to provide an adequate level of detail in some information
categories. A recent survey of existing PAs that have not h;
Sis indicates that the quality and quantity of data in sever
categories were inadequate, in particular:
o Site and operations history;
o Descriptions of hazardous conditions and
incidents;
o Estimates of quantities of contaminants; and
o Demography.
To ensure that the data gathered for new PAs support th
preliminary and projected HRS scores and facilitate subseque
activities, certain general data quality requirements apply.
The PA is limited to available information and whatever new
can be developed through off-site reconnaissance. Formal
site-specific data collection plans and data quality object!
that are applicable in subsequent CERCLA activities are,
therefore, not appropriate for PAs. However, the investigat
should always evaluate how "good" the data are as they are k
collected to ensure their proper use. This is particularly
with analytical data. The data checklist identifies the ty|
of questions that the investigator should ask about analytic
data to determine how good the data are.
If answers to any of these questions indicate that eer
data are suspect, the lead agency should determine how best
use those particular quantitative data in the PA. It may b<
useful to consult persons with appropriate expertise in
evaluating data, such as analytical chemists, for matters
concerning analytical techniques.
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OSWER DIRECTIVE 9345.0-01
The usefulness and dependability of qualitative data, such
as maps, and geological and hydrogeological reports, must also
be evaluated. For these data, age and applicability to site
conditions are the major considerations. An investigator should
always be aware of how recent the data are. For example, a U.S.
Geological Survey (USGS) map may be useful in understanding the
drainage pattern of a site, but because many of the maps are
old, the map may not provide recent enough population data.
2.3.1.2 Information on Site History/Reaulatorv Status
During the review of technical information, the lead agency
should also examine information on the regulatory and
enforcement status of the site, including other Federal and
State regulatory and enforcement efforts. This examination may
determine whether the release or threatened release can be
addressed by a Federal program other than CERCLA.
The purpose of this effort is to begin to identify those
sites where releases may come under the jurisdiction of other
authorities. It is not necessary for the investigator to go out
of the way to collect this information but, while reviewing
available files for technical data, it is likely that regulatory
data will be available. This information will be valuable upon
completion of the SI to assess whether it is appropriate to
pursue cleanup via these .other authorities. There are two kinds
of sites where the regulatory status will actually preclude
further CERCLA remedial action: sites regulated under the
Uranium Mill Tailings Radiation Control Act (UMTRCA) and the
Atomic Energy Act (AEA). EPA is legally precluded from pursuing
further action at these sites. Thus, it is necessary to
determine whether sites come within the authority of these two
acts.
Under the Environmental Priorities Initiative, other sites
that meet or may meet NPL scoring requirements will receive
further evaluation through an SI even if they will eventually be
cleaned up under other authorities. At the time the SI is
completed, a determination will be made as to whether it is
useful and appropriate to pursue action under these other
authorities. When a site comes within the jurisdiction of one
of the other Federal regulatory programs listed above, the PA
can provide information on the regulatory and/or enforcement
status of the site. To review compliance with the requirements,
the lead agency may also consult the Regional or State office
staff in charge of the given program. The regulatory
information review must be documented in the PA report.
2.3.2 Site Reconnaissance
Experience suggests that site reconnaissance improves the
quality of PAs. Review of existing data should identify
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specific kinds of information that will be collected during
site reconnaissance. Site reconnaissance also affords an
opportunity to verify some kinds of data collected during •
information review.
*
The results of site reconnaissance, including photogr.
documentation of the site such as a photo location map, sh<
be part of the PA report.
2.3.2.1 Off-site Reconnaissance
Off-site reconnaissance, i.e., reconnaissance outside
boundaries of the release location, is now a routine compoi
of PAs. It affords the lead agency the opportunity to con:
"desk top" data, to interview local authorities, such as h<
department officials, to update site-condition information
to review local records. It also assists in determining tl
immediacy of the need for response.
During off-site reconnaissance, the lead agency shoul<
consider collecting information that will facilitate an SI
removal program action, such as:
o Health and safety factors for the
preparation of health and safety plans
for the FIT and for the protection of
the general public, if necessary;
o Legal and logistical information about
site access;
o Information about facility operation or
history from citizens living near the
site;
o Possible sampling locations; and
o Equipment, manpower, and mobilization
requirements.
2.3.2.2 On-Site Record Search and Interviews
Visits inside facility property boundaries to search
or interview site managers are to be distinguished from
reconnaissance of the actual area of contamination. On-s:
visits to search files or interview site managers can be i
whenever appropriate to collect information, provided pri<
access is acquired and any costs in delay and resources a:
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carefully balanced against the expected benefits. In general,
OSHA requirements are not applicable to file searches or
interviews and, therefore, health and safety plans need not be
prepared. In addition to gathering information directly
relevant to the PA during file searches and interviews, lead
agencies should make use of this opportunity, insofar as
possible, to elicit information about potentially responsible
parties (PRPs) for possible future enforcement action.
2.3.2.3 On-site Reconnaissance
Reconnaissance on-site to the actual area of contamination
should be evaluated very carefully and confined to exceptional
circumstances. On-site reconnaissance of the contaminated area
requires preparation of health and safety plans, which increases
cost and time requirements considerably and may delay completion
of the PA. As with on-site record searches and interviews,
prior site access must be acquired and lead agencies should
carefully balance the costs in terms of delay and use of
resources against the information that may be collected.
Reconnaissance of the contaminated area during a PA, therefore,
should be considered only when it is potentially a determinative
factor in deciding whether the site requires further CERCLA
remedial action.
At sites where no one is present at the location and little
or nothing is known about the nature or extent of contamination
(abandoned or uncontrolled sites), on-site reconnaissance during
the PA should not be considered.
2.3.3 Development of Preliminary and Projected HRS Scores
When the data have been collected from existing information
and site reconnaissance, the lead agency must perform an
analysis of the data, referred to as a Site Screening Analysis
(SSA). The SSA develops both preliminary and projected HRS
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scores.* After deriving the scores, the evaluator will use
to estimate what the site's score-will be at the end of an £
and that estimated score is used to establish the priority c
the site for further CERCLA pre-remedial action. (The prioi
setting process is described in Section 2.3.5 (p.16).)
The preliminary HRS score is developed from whatever he
data are collected and entered on the data checklist. Soeirc
of any data used to develop the preliminary HRS must be fon
documented and be of the quality that would satisfy HRS QA.
(Documentation requirements are discussed in Section 2.3.7
(p.19).) Because little hard data may be available, some
categories will have to be scored zero in the development 03
preliminary HRS. Lack of hard information may, therefore,
result in deflation of the preliminary HRS score.
The projected HRS score is a reasonable approximation c
what the score of the site could be. In developing the
projected score, the evaluator estimates values in the same
categories used in development of the preliminary HRS score
The evaluator is not limited, however, to the hard data uset
the preliminary HRS score. To fill in categories for which
there is little or no existing hard data, the evaluator
estimates a value based on a reasonable judgment of the dat.
available and a reasonable approximation of data that may b<
identified on further investigation. The reasonable estima-
thus can reflect the evaluator's experience with similar
releases or sites and also the probability that missing dat<
reasonably be collected during an SI. The projected score i
therefore, avoid the score deflation that occurs when zero
used for unavailable or undocumented data and decrease the
possibility of score inflation that results when maximum va
are entered to fill in gaps.
The preliminary and projected scores will then be used
assign a priority to the site for an SI or to eliminate the
from CERCLA remedial activity. Performing this type of ana
also serves other functions. Developing SSA HRS scores wil
* A computer program and user's guidance document for
SSA are being developed to facilitate the development of th
scores. (Many Regions currently use valid HRS pre-score
analysis techniques, but uniform use of a single analyti'c. t
will facilitate nationally consistent ranking of sites and
allocation of resources). Several Regions will test the SS
computer program during FY 88 to evaluate its usefulness an
applicability.
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OSWER DIRECTIVE 9345.0-01
identify gaps in the data required to qualify the site for the
NPL and can form the basis for developing a recommendation for
the study plan for site inspection.
2.3.4. Application .of Qualitative Criteria
The SSA score development process described above is based
on the existing HRS. Because the HRS is under revision, it is
appropriate that the SSA scores be accompanied by a qualitative
assessment of the new and expanded areas of ranking
considerations that are expected to be included in the revised
HRS.
In addition to requirements for gathering different types
of data and modification of the sampling/background data
collection strategy, four areas where greater emphasis is
anticipated in the revised HRS are:
o Actual or potential environmental
impacts;
o Potential contamination of the food chain;
o Risk from direct on-site exposure; and
o The potential for air releases.
Once the SSA scores have been developed, the existing
information should be reviewed to see if there is an indication
that the revised HRS concerns noted here may be significant at
particular site. If so, it may be reasonable to assume that tf.
SSA scores under a revised HRS approach would be higher, and
this should be taken into account when assigning the priority c
the site as described below. Revised HRS supplements in the
checklist included as Appendix B are designed to elicit
information useful for this qualitative assessment. (Interim
advisories on potential changes in the HRS are available in
SI/HRS bulletins.)
The SSA scores and qualitative criteria generally will be
the basis for site inspection categorization. Reasonable
judgment may indicate, however, that other site-specific facto:
should be used to supplement those decision tools. For example
a technical consideration, such as a finding that all wells
within 3 miles of an area of contaminated ground water are
upgradient from the site may tend to lower a site's priority.
On the other hand, a site may warrant a somewhat higher
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OSWER DIRECTIVE 9345.0-01
priority, if it is the subject of extensive public concern.*
2.3.5 Priorities for Site Inspections
»
Resources for conducting remedial Sis are limited, and t:
should be focused on those sites that pose the most serious
threats and that are most likely to satisfy the requirements
listing on the NPL. Therefore, following the derivation of s
scores and application of qualitative criteria, PA sites must
assigned priorities to determine an appropriate order for fut
SI activity, if any.
After PAs, all sites must be placed in one of three
categories:
o High priority - This category will generally
comprise sites that are likely to score above
cut-off upon application of the current HRS at
the end of an SI. Sites with both preliminary
and projected HRS scores over the cut-off will
high priority sites. Sites with a pro-iected
score above the cut-off and a preliminary scor
near the cut-off may also be categorized as hi
priority.
o Medium priority - This category will generally
comprise those sites with a potential to score
above the cut-off upon application of the curz
HRS at the end of an SI. Sites with a project
score above the cut-off and a preliminary scoi
below will most probably be assigned medium
priority.
. * In this latter case, if this factor is not deemed •-
sufficiently significant to raise a site's priority, it may,
least, affect the timing of an SI at the site. The Region m;
wish to conduct an SI as quickly as possible to resolve cbno
of a community affected by a release.
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OSWER DIRECTIVE 9345.0-01
o No further remedial action planned (NFRAP1* -
This category represents all other sites and will
generally include (1) sites that never received
CERCLA hazardous substances; (2) sites where the
CERCLA hazardous substances are clearly not
releasing, and have no potential to release, into
the environment and no removal action is
required; (3) sites where EPA is not legally
authorized to respond to the release; and (4)
sites with no reasonable potential to score 28.5
or higher upon application of the current HRS at
the end of an SI. NFRAP sites will have both
preliminary and projected scores below the cut-
off.
A site with no potential to score 28.5 or higher should be
designated a NFRAP site and brought to the attention of the
appropriate State. If further analysis by a State indicates
that Federal Superfund response may be appropriate, the site can
be referred back to the Superfund program for recategorization.
Similarly, RCRA sites that do not appear likely to score
28.5 or higher will be referred back to the RCRA program for
attention.
Regional enforcement staff should be notified of sites
placed in the high priority category for initiation of PRP
search activities.
At sites where PRP investigation or actual site cleanup is
planned or underway as a result of State enforcement action, the
Region may choose to assign a lower priority to the site for an
SI. The status of PRP activities at such sites should be
included in the PA report. This will be useful when final
Agency policy concerning these sites is developed. At that
time, the sites may be eliminated from further CERCLA
consideration if the PRP action has been found appropriate.
Sites that potentially may require emergency removal actior
should be handled separately from this prioritization process ir
order to ensure timely and appropriate response.
* The NFRAP determination under the CERCLA pre-remedial
program does not indicate that action under another authority,
such as removal program action or enforcement action under RCRA
or CERCLA authorities-, may not be appropriate at a site.
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OSWER DIRECTIVE 9345.0-01
2.3.6 Report Content and Preparation
At the end of the PA, the investigator must prepare a :
report describing the site conditions and making a
recommendation regarding.any further action. This
recommendation 'must be justified based on the information
sources reviewed, site reconnaissance, SSA scores, gualitat.
criteria, and other site-specific factors used during the'p;
This will ensure reasonable consistency across PAs and that
PA and report support the recommended priority for site
inspection.
The PA report consists of a summary report and appropr:
attachments. The specific content of the summary will vary
based upon the amount of existing environmental and regulate
information, the nature of the site, and the final
recommendation. Attachments to the report should routinely
include maps, in particular, a field map of the facility anc
topographical map of the area of the facility.
The PA summary report should discuss: (1) site history
(2) waste descriptions; (3) pathway characteristics; and (4;
targets. Responses to the questions identified in the data
checklist (Appendix B) may be included in the PA summary re]
or attached in the form of an annotated data checklist. Afl
reasonable attempt is made, it may still be impossible to
collect all of the checklist information. The PA report she
note information that does not exist. (These data gaps at t
PA stage will form the basis of subsequent SI field work, iJ
SI is deemed necessary.) In other cases, the investigator i
conclude that it is unnecessary to collect data in a certai]
area. For example, if the air pathway is clearly not a vial
route for contaminant migration, then it is unnecessary to
collect data on air pathway factors. A decision that certa
data is unnecessary along with an appropriate justification
should be included in the PA report.
If information about PRPs is discovered during the PA,
should be made available to the Regional enforcement person.
responsible for PRP searches.* PRP information need not be
included in the PA report, however, it should be retained i
PA file.
*Please refer to the PRP Search Manual (OSWER Directiv
9834.6, August 1987) for additional information on PRP sear
during the pre-remedial process.
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OSWER DIRECTIVE 9345.0-01
The following format is suggested for PA reports prepared
initially or revised pursuant to this guidance:
o Name of site and site description.
o Recommendation regarding further action.
o Justification for recommendation.
o Summary of information from each part of the PA
data checklist (or an annotated checklist as an
attachment).
o Summary of site reconnaissance.
o Maps, photographs, and other appropriate
attachments.
EPA Form 2070-12 may be used at each Region's discretion (see
Appendix C). Detailed guidance on the format and contents of PA
reports will be developed shortly. This guidance will address
the issue of what PA information is considered "HRS
deliberative" and, therefore, not subject to public release.
2.3.7 Documentation
Most of the information compiled during the PA stage will
come from existing Federal, State, and local records, including
permit application data and compliance reports, as well as
non-site specific information available through sources
identified in Appendix A. The value of well-documented data and
information for both site decision purposes and HRS package
preparation cannot be over-emphasized. Historically, not all of
the information developed during the PA was referenced or
documented. When a site was subsequently scored under the HRS,
it was often necessary, therefore, to redevelop data and
re-identify sources, which sometimes added greatly to the cost
of the overall pre-remedial site characterization effort.
.Moreover, inadequate references and documentation made it
difficult at the time of the SI to determine what information
was needed.
Appropriate documentation for a PA consists of:
o Thoroughly referencing sources in the
report;
o Providing limited, relevant
attachments; and
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OSWBR DIRECTIVE 9345.0-01
o Maintaining complete project files.
A "source" should be referenced for each item of
information contained in the PA report. Only those sources the
are particularly significant should be routinely attached to tl
report. A copy of all source data, however, should be retainec
in the project file. The source could be copies of relevant
pages from a report, or a memorandum, trip report, or record ol
communication. All records of communication should be signed
and dated, the parties identified with titles and affiliations,
and a telephone number noted.
It may be useful to create a reference file for written
materials and prepare telephone logs for telephone conversatior
referenced. Logs could contain the site name; date; time;
caller's name; name, title, and telephone number of the person
called; and all other pertinent data. Wherever possible, the
person conducting the telephone interview should try to obtain
written confirmation of telephone conversations, either by
requesting a follow-up letter from the person interviewed, or I
preparing a letter summarizing the conversation and sending it
to the person interviewed for signature and return.
2.3.8 CERCLIS Tracking
A Region enters a site in CERCLIS as soon as possible aft<
it is notified of a potential hazardous waste release at the
site. CERCLIS generic data elements called events are then use<
to track the progress of various actions in the PA/SI process.
PA is the generic code for PAs and related data. The PA is
defined, for CERCLIS purposes, as the process for collecting a
documenting diverse existing information about the source and
nature of the site hazard. When the Region has reviewed and
accepted the PA report, the Region will enter the acceptance
date as the completion date for the PA. The Region will also
enter an event qualifier to indicate the results of the PA. I
FY 88, event qualifiers for PAs are:
H = high priority
M = medium priority
L = low priority
N = No further remedial action plajim
As was described in Section 2.3.5, sites ranked using th:
guidance will be assigned high or medium priority or classifie
as requiring no further action under the CERCLA remedial
program. When the PA is completed and the site has been
assigned a priority in accordance with this new ranking systei
the letter that corresponds to the priority assigned to the s:
should be entered. Regions should disregard the qualifier "lc
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OSWER DIRECTIVE 9345.0-01
priority" which will be deleted from the CERCLIS code in the
near future to reflect the priority system described in this
guidance.
3.0 GUIDANCE FOR REASSESSING EXISTING PAs
In light of the new standards of quality for PAs and the
new criteria for disposition of sites at the end of PAs
established by this guidance, and the fact that a number of PAs
were completed many years ago, it is prudent to reassess all PAs
for sites where no SI has been done. This one-time reassessment
of such PAs is designed to identify sites where: (1) the
disposition may change as a result of applying the new criteria;
or (2) the existing PA report is inadequate or sufficiently out
of date as to warrant redoing the PA. Reassessing these
previously completed PAs will bring such sites within the range
of current standards and ensure that all sites are categorized
using the same criteria, regardless of when the original PA was
done.
All PAs for sites where no SI has been done are candidates
for reassessment. Exactly which, among these PAs with no Sis,
are reassessed is at the discretion of the Region. Some Region:
may choose to review all these sites. Other Regions may choose
to reassess only the "low priority" sites if they believe that
this category may be the most weakly substantiated. However it
is performed, the reassessment should be completed in FY 88. Ii
performing the reassessment, the Region should assess whether:
o The PA is of adequate quality and contains
sufficient information to determine the
appropriate disposition of the site under the ne-
criteria; and
o The disposition assigned by the original PA is
appropriate under the new criteria.
Upon completion of the reassessment, all PAs where no Sis
have been done must be assigned to the high, medium, or no
further remedial action planned category or set aside for a new
PA. Sites designated as "low priority" after the original PA
must be placed in one of the categories or set aside for new
PAs. No sites designated "low priority" should remain after
reassessment. New PAs for sites set aside, or upgrading of PAs
where data are insufficient, should be conducted following the
PA procedures presented in this guidance. The schedule for
upgrading or redoing the set-aside PAs is at the Region's
discretion. Redoing or upgrading PAs does not necessarily have
to be completed in FY 88.
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OSWER DIRECTIVE 9345.0-01
4.0 GUIDANCE FOR HANDLING PUBLIC PA PETITIONS
4.1 Introduction and Background
CERCLA section 105(d), added by SARA, authorizes any pers
who is, or may be, affected by a release or threatened release
of a hazardous substance or pollutant or contaminant to petitd
the President to perform a preliminary assessment. The
authority vested in the President was delegated to the
Administrator of EPA and the heads of other appropriate
Executive departments and agencies by section three of Executi
Order No. 12580, dated January 23, 1987. The authority was
further delegated to the Regional Administrators by EPA interr
delegation No. 14-17-B dated September 15, 1987.
Petitions may be received from individuals or groups and
are likely to vary considerably in the level of information
provided and the type of release identified. When petitions a
received, each Region will be responsible for handling the
petitions that concern sites located within its area, except f
those involving releases from Federal facilities which will be
addressed by the appropriate Federal agencies. Regions can
conduct PAs directly or can authorize States to conduct them i
the State and the Region enter into a cooperative agreement ir
which the State agrees to complete the PA within 12 months of
the receipt date of the petition. EPA wants to encourage the
public to pursue State or local action before using the PA
petition process to bring the site to Federal attention.
4.2 Statutory Requirements
CERCLA section 105(d) establishes three statutory
requirements for the PA petition process:
(1) The petitioner must be a person who is,
or may be, affected by a release or
threatened release of a hazardous
substance or pollutant or contaminant;
(2) If a preliminary assessment of the
release that is the subject of the
petition has not been previously
conducted, the Agency shall, within 12
months after the receipt of any such
petition, complete the assessment or
provide an explanation of why the
assessment is not appropriate; and
(3) If the preliminary assessment indicates
that a release or potential release may
pose a threat to human health or the
environment, the Agency shall promptly
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OSWER DIRECTIVE 9345.0-01
evaluate such release or threatened
release in accordance with the hazard
ranking system (HRS) referred to in
paragraph (8)(A) of subsection 105(a)
to determine the national priority of
such release or threatened release.
Proposed regulations governing PA petitions are expected to
appear in the upcoming proposed NCP revisions. Regions can,
however, expect to receive petitions before final regulations
PA petitions are promulgated, therefore, the statutory
requirements and proposed regulatory provisions are incorporat
in the criteria and procedures for handling petitions found in
Appendix D.
5.0 CONTACTS FOR FURTHER INFORMATION
Questions regarding PA preparation and reassessment shoul
be directed to Lucy Sibold, FTS 382-2454. Questions concernin
public PA petitions should be directed to Kevin Donovan, FTS
475-9749.
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OSWER DIRECTIVE 9345.0-01
APPENDIX A: INFORMATION SOURCES
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INFORMATION SOURCES FOR PRELIMINARY ASSESSMENT/SITE INSPECTION/MRS SCORING
SOURCE
A. U.S. DEPARTMENT OF THE INTERIOR
I. U.S. Geologic Survey (USGS)
Central and Regional OH ices
TYPE OF INFORMATION
Geologic Maps
Orllwpholo Maps
Topographic Maps (latitude, longitude, slope,
wetland determination, surface drainage,
migration pathway identification)
Aerial Photos
National Parks, Monuments, Recreation Areas
and Historic Sites Map
Land Use and Land Cower Data
Technical Geologic/Hydrogeologic Reports
Water-Resources Investigations and Water-
Supply Data
Hydrologic Mapping
Generic Geophysical Data
Gauging Station Data
Water Discharge Records
Flood Prone Area Maps
Historical and Out-of-Print Maps
NOTES
Full U.S. Coverage
Oilers 7-1/2° and 15° Maps; 7-1/2° MoM
Valuable.
Useful in determining site boundaries, l.ind use
calculating waste quantities and evaluating site
operations both past and present.
• Tend to be regionalized.
May be useful in determining site bounil.iries.
• May he useful in determining stream
and evaluating discontinuities.
May be used to identify potenti.il wcil-ux
areas.
May help evaluate site operations .is
enisled at the time of operation.
May help evaluate site operations .is
existed at the time of operation.
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I. INFORMATION SOURCES FOR PRELIMINARY ASSESSMENT/SITE INSPECTION/MRS SCORING
SOURCE
B. U.S. DEPARTMENT OF AGRICULTURE
I. Soil Conservation Service (STS)
OH ices located in every county
2. Agricultural Stabilization and
Conservation Service (ASCS)
OH ice co-located with the SCS
ollices
C. U.S. DEPARTMENT OF THE INTERIOR
I. Fish and Wildlife Service
D. U.S. DEPARTMENT OF HOUSING
AND URBAN DEVELOPMENT
E. U.S. DEPARTMENT OF COMMERCE
I. Bureau ol Ilie Census
TYPE OF INFORMATION
Soil Surveys
Soil Maps and Aliases (permeability, soil pll,
depth to water table)
Crop Records
Irrigated Acreage
National Wetlands Inventory Maps
Federally Endangered Species Data
Records and Fish Kills
Habitat and Resource Information
Flood Insurance rate maps
Current Figures and Demographics
Congressional District Atlas
NOTES
Generally describe only upper 5 lo f. II. nl soil.
Distinguish between lood/loragr rr»|» irrigation
and watering ol furl.
May identity potential wetland arc.is.
• Use 1980 census data.
• Uselul in determining population < rulers.
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INFORMATION SOURCES FOR PRELIMINARY ASSESSMENT/SITE INSH t TION/IIRS SCORING
SOURCE
F. U.S. AHMY COUPS Olr ENGINEERS
TYPE OF INFORMATION
Wcll.md Drierinin.ttions
DtniipMig Records
Dis< liargr Record)
Arrial Photo*
Flood Prone Area Maps
NOTES
* Useful in determining site boimd.uirs l.md use
< air ula I ing waste quantities and rv.iln.iling site
operations both past and present.
• May identify potenti.il wetland
G. U.S. F.NVIKONMENTAL PROTECTION
AGENCY
I. Regional Olli< cs
RCUA Permits and Applications
NPDES Permits, Applications, Reports, and
Notices ol Violation
Air Prrmits, Applications, and Reports
CERCLA Actions
TSCA Records
Enforcement Actions
Surface Water and Groimdwalcr Reports
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INFORMATION SOURCES TOR PRELIMINARY ASSESSMENT/SITE INSPECTION/MRS SCORING
SOURCE
I. Regional Offices (continued)
2. Environmental Photographic
Interpretation Center (CPIC)
II. NATIONAL OCEANIC AND ATMOSPHERIC
ADMINISTRATION
TYPE OF INFORMATION
Site History
Site Owner/Opera tor Information
Previous Site Inspection Information
Waste Generators and Transporters
Waste Containment/Eaten! ol Contamination
Aerial Photography and Interpretation
Special Mapping
Climatic data (I yr., 7*-hour rainfall,
seasonal .tnd annual precipitation and
evaluation figures)
NOTES
fie sure data meets regional OA/QC
requirements.
Useful in determining site boundaries, l-ind
use, calculating waste quantities and
evaluating site operations both past and
present.
A minimum of 10-year averages required l»r
seasonal figures.
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INFORMATION SOURCES I OR PRELIMINARY ASSESSMENT/SITE INSPECTION/MRS SCORING
SOURCE
STATE EPA Orril.ES OK EQUIVALENTS
(Water Resources, Solid Waste
and Geology Department*)
J. STATE DEPARTMENT OF
TRANSPORTATION
TYPE OF INFORMATION
Permits
Previous Site Inspection Information
Waste Quantity Estimates
Site Owner
Operator In lor mat ion
Water Supply Data
Sampling and Monitoring Data
Surlace Water and Groundwater Reports
Well Logs and Soil Boring Data
Aquiler Information
Air and Solid Waste Files
State and County Map
NOTES
Federally permitted releases (i.e.,
not eligible for MRS consideration.
Wastes granted state permits m.iy \lill I in-
eligible lor consideration.
Containment of waste.
May differ from site owner.
Oe sure data meets QA/QC requircnici-is.
Use lo determine aquiler interconnect ii»n.
May be necessary in cases where IISC.S m.i|>s
are outdated.
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INFORMATION SOURCES FOR PRELIMINARY ASSESSMENT/SITE INSPECTION/MRS SCORING
SOURCE
K. COUNTY OFFICES
I. Assessor
2. Health Department
1. Planning Commission/City Engineer
%. Zoning Department
TYPE OF INFORMATION
Plat maps (distance to nearest oil-site
building, land use, distance to nearest
population figures, number ol buildings in
a 2-mile radius
Land Ownership
Facility Inspection kilormalion
Water Supply Data
Sampling and Monitoring Data
Waste Generators and Transporters
Complaints/Prior Releases
Permits
Site Plans
Liquid Waste Discharge Data
Land Use
Acri.il Photos
Land Use
NOTES
Permission to access site must be obtained
Irom the current landowner.
Also check il bottled water is being us<-d due
lo contamination
De sure data meets QA/QC requirements.
May be useful in calculating the
capacity ol lagoons/surlace, impoundments.
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INFORMATION SOURCES FOR PRELIMINARY ASSESSMENT/SITE INSPIiCTION/IIRS SCORING
SOURCE
K. COUNTY OFFICES (continued)
>. Road Commission
6. Agricultural Extension Ollice
TYPE OF INFORMATION
NOTES
L. LOCAL OFFICES
I. Fire Department
Loc.il Maps
Aerial Photos
Aerial Photos
Land Use Data
Irrigated Acreage
Fire History
Ei plosion
Contingency Plans
Complaints
Inspection Data
Distinguish between lood/forage rco|> nutation
watering ol turf.
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May use to determine if site is a rcrlihc
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I. INFORMATION SOURCES FOR PRELIMINARY ASSESSMENT/SITE INSPECTION/MRS SCORING
SOURCE
LOCAL OFFICES
2. Water and Sewer Departments
1. Electrical Utility Companies
*. Chamber ol Commerce
5. Citizens/Neighbors/
Former Company Employee
TYPE OF INFORMATION
Location ol Sewers and Buried Mains
Water Intake and Well Location Data
Population Served Figures
Aquifer Data
Well Depth*
Location ol Buried Lines
Site Ownership
Local Industry Information
Site Ownership History
Site Activities
Census Figures and Demographics
Site Activities and History
Waste Quantity Estimates
Site Accessibility
Site Owner/Operator Information
Site Fires or Explosions
Complaints or Incidents
NOTES
Check before drilling.
• Check before drilling.
• Identify other potential sources of
contamination.
• Use 1980 census data.
• Be sure those interviewed are reliable
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INFORMATION SOURCES FOR PRELIMINARY ASSESSMENT/SITE INSPECTION/MRS SCORING
SOURCE
LOCAL OFFICES (continued)
6. Company Records and Site Officials
7. Newspapers
B. Trucking and Hauling Companies
TYPE OF INFORMATION
Production Records
Waste Type and Quantity
Generator Records
Site History
Owner/Operator Information
Site Accessibility
Waste Containment Data
Spill Records
Permits
Waste Storage and Disposal Methods
Site History
Complaints
Generator and Transporter Data
Waste Type and Quantity
NOTES
• Check sources
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INFORMATION SOURCES FOR PRELIMINARY ASSESSMF.NT/SITE INSPECTION/I IKS SCORING
SOURCE
LOCAL OFFICES (continued)
9. Well Drillers
10. Consultants
II. Airports
12 Universities
TYPE OF INFORMATION
Well Locations
Well Logs and Soil Boring Data
Local Soil Geology
Water Table and Aquifer Data
Water Supply Information
Permeability Figures - Soil
Surface Water and Ground water Reports
EN lent ol Contamination
Special Studies
Sampling and Monitoring Data
Climatic Data (I -year, 24-hour rainfall,
seasonal and annual precipitation and
evaporation figures)
Surface Water and Groundwatcr Studies
Sampling and Monitoring Dal.i
Clim.ilic Data (I -year, 2"»-honr rainfall,
seasonal and annual precipitation and
evaporation figures)
NOTES
he sure those interviewed are reliable \nmrcs.
Re sure conclusion drawn are based on sound
professional judgements before using.
• De sure data meets QA/QC requirements.
Be sure data meets QA/QC requirements.
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INFORMATION SOURCF.S FOR PRELIMINARV ASSESSMENT/SITE INSPECTION/MRS SCORING
SOURCE
M. CLIMATIC DATA KCFERENCES
I. Climatic Alias ol the United Slates,
U.S. Department of Commerce,
National Climatic Center,
Ashe»ille, North Carolina. 1979
2. Rainfall Frequency Allatol
the United State*, Technical
Paper No. *0, U.S. Department ol
Commerce, U.S. Government Printing
Ollice, Washington, D.C. 196)
TYPE OF INFORMATION
Annual Precipitation and Evaporation Maps
I-year, ?*-hour Rainfall Map.
NOTES
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N. TOXICOLOGY AND HAZARDOUS SUBSTANCE
REFERENCES
I. Chemical Hazard Response
Information System
2. Hamilton and Hardy, Industrial
ToKicolony
). Sa«, Dangerous Properties of
industrial Materials, »th, >th"or
6th Editions
4. Patty. Industrial Hygiene and
Incompatibility, Physical Stale,
Flammability and Health Hazards
Toxicology
ToHicity
Toxicology
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INFORMATION SOURCES FOR PRELIMINARY ASSESSMENT/SITE INSPECTION/MRS SCORING
SOURCE
N. TOXICOLOGY AND HAZARDOUS SUBSTANCE
REFERENCES (continued)
>. ACGTM, Threshold Limit Values
lor Chemical Substance* and
Physical Agents in the Work
Environment, 191 *-X
6. Miedl, Hazardous Materials Handbook
7. Mauley, Condensed Chemical Dictionary
I. The Merck lnde«
9. CRC Handbook ol Chemistry and Physics
10. NFPA Hazardous Material Manual
II. JRB Associates, Methodology lor Rating
the Hazard Potential ot Waste Disposal
STicT
12. Hazardous Watte ManaRemenl Law,
Regulations, and Guidelines lot
the Handling ol Hazardous Watte;
California Department of Health,
Sacramento. California,
February 197)
TYPE OF INFORMATION
NOTES
TLV*
Describes Processes and Generic Names
Physical State, CAS numbers
Physical Stale
Toiicity, Ignilability and Reactivity
Persistence
Incompatibility
O
CO
O
H
3
i
u>
Ol
•
O
I
O
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9345.0-01 OSWER DIRECTIVE
APPENDIX B: DATA CHECKLIST
-------
9345.0-01
OSWER DIRECTIVE
PRELIMINARY ASSESSMENT (PA) CHECKLIST
INSTRUCTIONS: The checklist is intended to serve two main objectives:
(1)To quickly identify those items that have the greatest impact on the
potential for a site to score under the current and revised MRS, and
(2) To provide the more detailed information needed to prepare preliminary
and projected HRS scores using the site screening analysis (SSA)
methodology.
The twelve major information items that most directly impact the first objective
above are highlighted in bold type. The remaining items on the checklist are
designed to track closely with the input information requirements of the SSA.
You are not expected to have all of the information identified in the checklist. As
discussed in section 2.3.1.1 of the FY88PA Guidance Document, it may be impossible
to obtain certain information without undertaking more detailed field work
beyond the routine visual inspection conducted during the PA. However, within
the average time constraints of a PA, the investigator should try to obtain as much
information as possible.
Each migration pathway identifies items pertinent to the existing HRS and the draft
proposed revisions to the HRS. The HRS will likely change in response to public
comments on the proposed revisions; thus, some of the items on the checklist will
change. However, they should facilitate the evaluation of each pathway when it
becomes final. It is the intent of the supplementary sections to present the general
information to EPA, state, and contractor personnel so that potentially important
revised HRS data can be reviewed and considered in PAs done under this FY 88
guidance.
A referenced source should be cited for each checklist item. Referenced sources can
range from visual observation, to a record of communication, to an unpublished or
published document or report.
B-1
-------
9345.0-01
OSWER DIRECTIVE
PA CHECKLIST
I. SITE BACKGROUND INFORMATION
O Site name
O Site number
O Address
O Coordinates (latitude and longitude in degrees, minutes, seconds
township and range numbers)
O Directions to site (starting from nearest public road)
II. RESPONSIBLE PARTIES
O Owner
O Address (current and past, if available)
O Telephone number
O Operator
O Operator's address
O Operator's telephone number
O Type of ownership (specify private, Federal, state, county, municipal)
III. OVERVIEW/SITE HISTORY
O Site operations
- history/years of operation
- nature of operations (manufacturing, waste disposal, storage, etc.)
•
O Description of any emergency or remedial actions that have occurred a
site
O Description of any prior spills
O Description of relevant permitting matters
O Description of existing sampling and analysis data and brief summai
data quality
B-2
-------
O Evaluate the data quality for the following:
- sample objective
- age/comparability
- analytical methods
- detection limits
- QA/QC
IV. WASTE CONTAINMENT/HAZARDOUS SUBSTANCE IDENTIFICATION
O Describe as specifically as possible the methods of hazardous substance
disposal, storage, or handling.
• Describe the condition/integrity of each storage disposal feature o
structure. Evaluate from the perspective of each migration pathway (e.g.
ground water pathway - nonexistent natural or synthetic liner, corrodinc
underground storage tank; surface water - inadequate freeboard
corroding bulk tanks; air- unstabilized slag piles, leaking drums, etc.).
O Describe any secondary containment features/structures (such as run-oi
diversion system, leachate collection systems).
O Describe size/volume of all features/structures that contain hazardou
substances or volume of previously reported spills.
O Describe as precisely as possible existing permits and the types of hazardou
substances handled on site.
• Discuss any records or manifests which provide data on volume o
hazardous substances handled/disposed/released on site.
V. GROUND WATER PATHWAY
• Determine if ground water within fouri miles of the site is used for any c
the following purposes (if the answer to this is "unusable," then it is nc
necessary to answer the following questions).
- private or public drinking water source
- commercial
- irrigation (5-acre minimum)
• industrial
- not used, but usable
- unusable
• Determine the population drinking ground water drawn from wells with
fouM miles of the site.
• Identify nearest well within four1 miles that is a source of drinking water.
O Discuss known or probable ground water flow direction, if possible.
-------
• As precisely as possible, describe the geology and hydrogeology of the
area (including names, thickness, types of material and depth from
surface, including soils).
O Discuss any evidence of discontinuities between aquifers/aquitards within
fouH miles of the site.
O Discuss any evidence of interconnections between aquifers within twoj
miles of the site.
O Estimate annual net precipitation (by summing monthly values).
O Discuss soil or geological conditions that might inhibit or facilitate ground
water migration.
O Discuss, if possible, alternative water supply sources that are readily
available.
• Discuss any qualitative, quantitative, or circumstantial (e.g., closure of a
well) evidence of a release to ground water.
VI. ADDITIONAL FACTORS BASED ON DRAFT PROPOSED REVISIONS TO THE MRS
FOR THE GROUND WATER PATHWAY
O Identify if any underlying aquifers are "sole source" aquifers as designated
according to Section 1424(e) under the Safe Drinking Water Act.
O Determine if the site is located in an area of karst terrain.
VII. SURFACE WATER PATHWAY
O Describe surface water bodies of concern within the 151-mile target
distance limit.
O Discuss the probable surface runoff patterns from the site to surface
waters.
O Discuss whether the facility is located in surface water (e.g., marsh, swamp)
or a floodplain.
O From a topographic map, calculate and discuss the slope between the point
where hazardous substances begin to migrate and the probable point of
entry into the surface water body.
O Identify if surface water drawn from intakes within 151 miles from the
probable point of entry is used for any of the following purposes:
irrigation of commercial food or forage crops (5-acre minimum)
- commercial livestock watering
- commercial food preparation
- commercial/industrial purposes other than drinking water, recreation
or fishery uses
-------
• Identify and discuss the nature and size of any of the following targets
within the 151-mile target distance limit:
• population served by intakes drawing drinking water
• population associated with recreational use2
- sensitive environments (including fresh water or coastal wetlands IB-
acre minimum] and critical habitats of a federally-designated
endangered species)
- economically important resources (e.g., shellfish)2
• Discuss any qualitative, quantitative, or circumstantial (e.g., contaminated
surface water downstream of the site) evidence of a release to surface
water.
VIII. ADDITIONAL FACTORS BASED ON DRAFT PROPOSED REVISIONS TO THE HRS
FOR THE SURFACE WATER PATHWAY
O From a topographic map, estimate the size (in square miles) of the
upgradient drainage area from the site.
O Discuss the average annual stream-flow in the vicinity of the site.
O Discuss any biological sampling that might assess the food chain and
recreational impacts.
O If fisheries (recreational or commercial) exist within the 15-mile target
distance limit, assess each of the following:
- acreage of oceans, large lakes, or rivers
- acreage of ponds or lakes fed by low-volume streams
IX. ADDITIONAL FACTORS BASED ON DRAFT PROPOSED REVISIONS TO THE HRS
FOR THE AIR PATHWAY
O Determine the population within a four-mile radius of the site (allocated in
1/4,1/2,1, 2, 3,4-mile ring distances).
• Determine the distance to the nearest residence or regularly occupied
building as measured from any onsite emission source. If on site,
determine how many residents or workers occupy the building.
O Determine the distance to the following land uses within a four-mile
radius:
- commercial/industrial
- residential
- schools
- parks
- agricultural
-------
O Identify, locate, and discuss any nearby fresh water or coastal wetlands
acre minimum) or critical habitats of a federally-designated endange
species that could be affected by a release.
• Discuss any quantitative or qualitative evidence of a release to air.
O Determine particulate source mobility value (see Figure 2-3 in the propo
rule).
X. ADDITIONAL FACTORS BASED ON DRAFT PROPOSED REVISIONS TO THE I
FOR THE ONSITE PATHWAY
• Discuss any qualitative or quantitative evidence of onsite :
contamination. If there is no evidence of onsite soil contamination, the
is not necessary to answer the following questions.
O Determine the onsite population (i.e., people living or attending schoc
day care on contaminated property).
O Determine the population within one mile of the site (i.e., individuals v
live or go to school within one mile of the site).
O Describe any restrictions/barriers on accessibility to onsite waste materia
O Identify and discuss any onsite terrestrial sensitive environments.
O Describe the area of surface contamination (both on and off site).
-------
NOTES
1. Distance based on draft proposed revisions to the MRS.
2. Factor based on draft proposed revisions to the MRS.
r» f
-------
OSWER DIRECTIVE 9345.0-01
APPENDIX C; EPA FORM 2070-12
-------
OSWER DIRECTIVE 9345.0-01
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
PART 1 • SITE INFORMATION AND ASSESSMENT
i. IDENTIFICATION
01 STATE 02 SITE NUMBER
II. SITE NAME AND LOCATION
02 STREET. ROUTE NO.. OK SPEOFIC LOCATION OENTWER
OS OPCODE
Ofl COUNTY
07COUNT(f08 •
CODE
09 COOROMATES LATTTUOE
LONGITU06
10ORECTIOHSTOSnEiSi««n»»»i«
III. RESPONSIBLE PARTCS
01 OWNER tl
02 STREET rtM
03CITV
04 STATE
OSflPCOOE
06 TELEPHONE NUMBER
I I
07 OPERATOR r(Mo«»M<••«•» dono
08 STREET flu
09 CITY
10 STATE
12 TELEPHONE NUMBER
13 TYPE OF OWNERS** lC»*ct an*t
C A PRIVATE C B FEDERAL:
2 f. OTHER:
C C. STATE GO COUNTY C E. MUNJOPAL
C G UNKNOWN
14 OWNER/OPERATOR NOTWCATON ON ft£ iOwa««Mr«
C A RCRA3001 DATE RECEIVED: 1 I_
3 B. UNCONTROLLED WASTE SITEictnci* 'iici DATE RECEIVED:
D C.NO
IV. CHAMACTERIZATION OF POTENTIAL HAZARD
010N9TEMSPECTION
G YES DATE .
INO
MONTM OAT
C A. EPA C B. EPA CONTRACTOR ~ C STATE
C E. LOCAL HEALTH OFFICIAL C F OTHER:
Q D. OTHER CONTRACTOR
CONTRACTOR NAME(S):
02 SITE STATUS'CMoow
~ A ACTIVE G B. WACTTVE Q C. UNKNOWN
03 YEARS OF OPERATION
VEA* EMXNC mm~**»t
C A. MtQH C B MEDIUM
D C. LOW
I 0. NONE
VI. INFORMATION AVAILABLE FROM
01 CONTACT
02 OF I««MIC».
I )
04 PERSON RESPOMSOLE FOR ASSESSMENT
OS AGENCY
M ORGANBATION
07 TELEPHONE NUMBER
I )
OS DATE
EP* FORM 20rO-12|7-S1)
C-l
-------
OSWER DIRECTIVE 9345.0-01
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
PART 2 • WASTE INFORMATION
I. IDENTIFICATION
01 STATE 02 SITE NUMBER
II. WASTE STATES, QUANTITIES. AND CHARACTERISTICS
Ot PHYSICAL STATES 'C**c>«lM>
• tor CMS
CATEGORY
01 FEEDSTOCK NAME
02 CAS NUMBER
CATEGORY
; > FEEDSTOCK NAME
02CASNUI
FDS
FDS
FDS
FDS
PDS
FDS
FDS
FDS
VI. SOURCES OF INFORMATION «. >«•• I«KO««. -
EPA FOAM 2070-12 i7 8H
C-2
-------
OSWER DIRECTIVE 9345.0-O1
^ _-^. POTENTIAL HAZARDOUS WASTE SITE
AFP>\ PRELIMINARY ASSESSMENT
^^^' ** PART 3 • DESCRIPTION OF HAZARDOUS CONDITIONS AND INCIDENTS
1. IDENTIFICATION
01 STATE
02 SITE NUMBER
II. HAZARDOUS CONOfTIONS AND INCIDENTS
01 - A GROUNOWATER CONTAMINATION 02 C OBSERVED IDATF j - B
01 P
-------
OSWER DIRECTIVE 9345.0-01
A ..... POTENTIAL HAZARDOUS WASTE SITE ' IDENTIFICATION
tfVtHpA PRELIMIN*
^^k.1 f-1 PART 3- DESCRIPTION OF HAZ
ARY ASSESSMENT °1 STATE °2 «« "*«*"
ARDOUS CONDITIONS AND INCIDENTS
IL HAZARDOUS CONDfTIONS AND INCIDENTS -co-,~«,
01 G J. DAMAGE TO FLORA
04 NARRATIVE DESCRfDON
01 C K. DAMAGE TO FAUNA
04 NARRATIVE DESCPJPTION IHCUM «m«ti .««„.< ,.«,„„ ' .
EPA FOAM 2070-121^-8 H
C-4
-------
OSWER DIRECTIVE 9345.0-01
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
General Information
The Potential Hazardous Waste Site, Preliminary Assess-
ment form is used to record information necessary to make
an initial evaluation of the potential risk posed by a site and
to recommend further action.
The Preliminary Assessment form contains three parts:
Parti - Site Information and Assessment
Pan 2 — Waste Information
Part 3 — Description of Hazardous Conditions and Inci-
dents
Part 1 - Site Information and Assessment contains all of
the data elements also contained on the Site Identification
form required to add a site to the automated Site Tracking
System (STS). It is therefore possible to add a site to STS at
the Preliminary Assessment stage. Instructions are given
below.
Part 2 - Waste Information and Part 3 - Description of
Hazardous Conditions and Incidents are used to record specific
information about substances, amounts, hazards, and targets.
e.g., population potentially affected, that are used in determin-
ing the priority for further action. Parts 2 and 3 are also con-
tained in the Potential Hazardous Waste Site, Site Inspection
Report form where they maybe used to update, add, delete, or
correct information supplied on the Preliminary Assessment.
An Appendix with feedstock names and CAS Numbers
and the most frequently cited hazardous substances and CAS '
Numbers is located behind the instructions for the Preliminary
Assessment.
General Instructions
1. Complete the Preliminary Assessment form as com-
pletely as possible.
2. Starred items (*) are required before assessment
information can be added to STS. The system will not accept
incomplete assessment information.
3. To add a site to STS at the Preliminary Assessment
stage, write "New" across the top of the form and complete
items 11-01. 02, 03. 04. and 06, Site Name and Location, and
item 111-13. Type of Ownership.
4. Data items carried in STS, which are identical to
those on the Site Identification form and which can be added,
deleted, or changed using the Preliminary Assessment form.
are indicated with a pound sign (*). To ensure that the proper
action is taken, outline the item(s) to be added, deleted, or
changed with a bright color and indicate the proper action
with "A" (add), "D" (delete!, or "C" (change).
5. There are two options available for adding, deleting,
or changing information supplied on the Preliminary Assess-
ment form. The first is to use a new Preliminary Assessment
form, completing only those items to be added, deleted, or
changed. Mark the form clearly, using "A", "D", or "C". to
indicate the action to be taken. If only data carried in STS are
to be altered, the Site Source Data Report may be used. Using
the report, mark clearly the items to be changed and the
action to be taken.
Detailed Instructions
Part r Site Information and Assessment
1. Identification: Identification (State and Site Num-
ber) is the site record key, or primary identifier.
for the site. Site records in the STS are updated
based on Identification. It is essential that State
and Site Number are correctly entered on each
form .
*l-01 State: Enter the two character alpha FIPS code for
the state in which the site is located. It must be
identical to State on the Site Identification form.
'1-02 Site Number: Enter the ten character alphanumeric
code for sites which have a Dun and Bradstreet or
EPA "user" Dun and Bradstreet number or the ten
character numeric GSA identification code for fed-
eral sites. The Site Number must be identical to the
Site Number on the Site Identification form.
II. Site Name and Location: If Site Name and Location
information require no additions or changes, these
items are not required on the Preliminary Assess-
ment form. However, completing these items will
facilitate use of the completed form and records
management procedures.
4HI-01 Site Name: Enter the legal, common, or descriptive
name of the site.
*ll-02 Site Street: Enter the street address and number (if
appropriate) where the site is located. If the precise
street address is unavailable for this site, enter brief
direction identifier, e.g., NW intersection I-295 &
US 99; Post Rd. 5 mi W of Rt. 5.
*tl-03 Site City: Enter the city, town, village, or other
municipality in which the site is located. If the site
is not located in a municipality, enter the name of
the municipality (or place) which is nearest the site
or which most easily locates the site.
*ll-04 Site State: Enter the two character alpha FIPS code
for the state in which the site is located. The code
must be the same as in item 1-01 .
all -05 Site Zip Code: Enter the five character numeric zip
code for the postal zone in which the site is located
*ll-06 Site County: Enter the name of the county, parish
(Louisiana), or borough (Alaska) in which the site is
located.
•I 1-07 County Code: Enter the three character numeric
FIPS county code for the county, parish, or bor-
ough in which the site is located. (The regional data
analyst will furnish this data item.)
»ll-08 Site Congressional District: Enter the two character
number for the congressional district in which the
site is located.
1 1-09 Coordinates: Enter the Coordinates, Latitude and
Longitude, of the site in degrees, minutes, seconds
and tenths of seconds. If a tenth of a second is in-
significant at this site, enter "0".
11-10 Directions to Site: Starting from the nearest public
road, provide narrative directions to the site.
C-5
-------
P»rt 2 (continued)
OSWER DIRECTIVE 9345.0-01
PRELIMINARY ASSESSMENT
example, do not measure the same amounts of
waste as both tons and cubic yards.
* 11-03 Waste Characteristics: Check all appropriate entries
to indicate the hazards posed by waste at the site.
If waste at the site poses no hazard, check Not
Applicable.
III. Waste Category: General categories of waste typi-
cally found are listed here. Enter the estimated gross
amount of the category of wane next to the appro-
priate substance name and enter the unit of measure
used with the estimate.
'111-01 Gross Amount: Gross Amount is the estimate of the
amount of the waste category found at the site.
Estimates should be furnished in metric tons (MT).
tons (TN). cubic meters (CM), cubic yards (CY).
drums (OR), acres (AC), acre feet (AF). liters (LT),
or gallons (GA). Enter the estimated amount next
to the appropriate waste category.
'III-02 Unit of Measure: Enter the appropriate unit of mea-
sure: MT (metric tonsl.TN (tons). CM (cubic meters),
CY (cubic yards), OR (number of drums). AC
(acres). AF (acre feet). LT (liters), or GA (gallons).
next to the estimate of gross amount.
III-03 Comments: Comments may be used to further ex-
plain, or provide additional information, about par-
ticular waste categories.
IV. Hazardous Substances: Specific hazardous, or
potentially hazardous, chemicals, mixtures, and
substances found at the site are listed here. This
information may not be available at the Preliminary
Assessment stage. Substances for which information
is available are to be listed here. For each substance
listed those data items marked with an "at" sign
(@) must be included.
@IV-01 Category: Enter in front of the substance name the
three character waste category from Section III
which best describes the substance, e.g., OLW (Oily
Waste).
QIV-02 Substance Name: Enter one of the following: the
name of the substance registered with the Chemical
Abstract Service, the common or accepted abbre-
viation of'the substance, the generic name of the
substance, or commercial name of the substance.
<§>IV-03 CAS Number: Enter the number assigned to the
substance when it was registered with the Chemical
Abstract Service. Refer to the Appendix for most
frequently cited CAS Numbers. CAS Numbers must
be furnished for each substance listed. If a CAS
Number for this substance has not been assigned,
enter "999".
@IV-04 Storage/Disposal Method: Enter the type of storage
or disposal facility in which the substance was
found: SI (surface impoundment, including pits,
ponds, and lagoons), PL (pile), OR (drum), TK
(tank), LF (landfill), LM (landfarm). 00 (open
dump).
IV 05 Concentration: Enter the concentration of the sub-
stance found in samples taken at the site.
IV 06 Measure of Concentration: Enter the appropriate
unit of measure for the measured concentration of
the substance found in the sample, e.g., MG/L.
UG/L.
V. Feedstocks
V-01 Feedstock Name: If feedstocks, or sub
derived from one or more feedstocks, are :
at the site, enter the name of each feedstock
See the Appendix for the feedstock list.
V-02 CAS Number: Enter the CAS Number fc
feedstock named. See the Appendix for fe<
CAS Numbers.
VI. Sources of Information: List the sources i
obtain information for this form. Sources cite
include: sample analysis, reports, inspection'
cial records, or other documentation. Source
provide the basis for information entered <
form and may be used to obtain further mforr
about the site.
Part 3 Description of Hazardous Conditions and Im
•I. Identification: Refer to Pan 1-1.
II. Hazardous Conditions and Incidents:
11-01 Hazards: Indicate each hazardous, or pou
hazardous, condition known, or claimed, to <
the site.
11-02 Observed. Potential, or Alleged: Check Ot
and enter the date, or approximate date, of
rence if a release of contaminants to the en
ment, or some other hazardous incident, is H
to have occurred. In cases of a continuing r
e.g.. groundwater contamination, enter the
or approximate date, the condition first b
apparent. If conditions exist for a potential r
check potential. Check Alleged for hazardo
potentially hazardous, conditions claimed tc
at the site.
11-03 Population Potentially Affected: For eacr
ardous condition at the site, enter the num
people potentially affected. For Soil enter the
ber of acres potentially affected.
11-04 Narrative Description: Provide a narrative c
tion, or explanation, of each condition. Inciu
additional information which further explai
condition.
11-05 Description of Any Other Known, Potential.
leged Hazards: Provide a narrative descnpt
any other hazardous, or potentially haza
conditions at the site not covered above.
III. Total Population Potentially Affected: Em
total number of people potentially affected ;
existence of hazardous, or potentially haza
conditions at the site. Oo not sum the ni
shown for each condition. * *
IV. Comments: Other information relevant to ob
potential, or alleged hazards may be enter*.
V. Sources of Information: List the sources t
obtain information for this form. Source;
may include: sample analysis, reports, inspe
official records, or other documentation. S
cited provide the basis for information e
on the form and may be used to obtain fun
formation about the site.
C-6
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OSWER DIRECTIVE 9345.0-01
Pin 1 (continued)
PRELIMINARY ASSESSMENT
ill.
•MI-01
•ill-02
•03
•04
-05
III-06
-------
OSWER DIRECTIVE 9345.0-01
APPENDIX
1. FEEDSTOCKS
CAS Number
1. 7664-41-7
2. 7440-38-0
3. 1309-64-4
4.744008-2
5. 1327-63-3
6.21109-854
7.7726-95-6
8. 108-894
9. 744043-8
10. 7782-60-6
11.12737-27*
12. 7440-47-3
13. 744O48-4
OMmtaaiNamt
Ammoni*
Antimony
Antimony Trioxide
Anenic
Arwnie Trioxide
Barium Sulf Ida
Bromina
Butadiena
Cadmium
Chlorine
Chromita
Chromium
Cobalt
II. HAZARDOUS SUBSTANCES
CAS Number Chemical Name
1 . 75-07-0
2.64-19-7
3. 108-24-7
4. 75-86-5
5. 506-96-7
6. 75-36-5
7. 107-02-8
8. 107-13-1
9. 124-04-9
10. 309-00-2
11. 10043-01-3
12. 107-184
13. 107-05-1
14.7664-41-7
15.63141-8
16. 1863-63-4
17. 1066-33-7
18. 7789494
19. 1341-49-7
20. 10192-30-0
21. 1111-78-0
22. 12125-02-9
23. 7788-98-9
24. 3012-65-5
25. 1382643-0
26. 12125-014
27.1336-214
28.6009-70-7
29. 16919-19-0
30. 7773464
31. 12135-76-1
32. 10198-04-0
33. 14307434
34. 1762-95-4
35. 7783-184
36. 62843-7
37. 62-53-3
38. 7647-18-9
39. 778941-9
40. 10025-91-9
41. 7783-56-4
42.130944-4
43. 1303-324
44. 1303-28-2
45. 7784-34-1
46. 1327-53-3
Aeataldehyde
Acetic Acid
Acetic Anhydride
Acetone Cyanohydrin
Acetyl Bromide
Acetyl Chloride
Acrolein
Acrylonitrile
Adipic Acid
Aldrin
Aluminum Sulfate
Allyl Alcohol
Ally) Chloride
Ammonia
Ammonium Acetate
Ammonium Benzoata
Ammonium Bicarbonate
Ammonium Bichromate
Ammonium Bifluoride
Ammonium Bisulfite
Ammonium Carbamate
Ammonium Chloride
Ammonium Chromete
Ammonium Citrate, Dibasic
Ammonium Fluoborata
Ammonium Fluoride
Ammonium Hydroxide
Ammonium Oxajate
Ammonium Silicofluorida
Ammonium Sulfaman
Ammonium Sulf ida
Ammonium Sulfita
Ammonium Tirtnte
Ammonium Thiocyanete
Ammonium Thiosulfite
Amyl Acetate
Aniline
Antimony Ptntachloride
Antimony Tribromide
Antimony Trichloride
Antimony Trifluoride
Antimony Trioxide
Anemc OitulfkJ*
Arsenic Pentoxide
Anenc Trichlorida
Artemc Trioxide
CAS Number
14. 1317-38-0
15. 7758-96-7
16. 1317-39-1
17. 7445-1
18. 7647-01-0
19. 7664-39-3
20. 1335-26-7
21.7439-974
22.74424
23.91-20-3
24. 7440-02-0
25. 7697-37-2
26. 7723-144
CAS Number
47. 1303-33-9
48. 54242-1
49.71-43-2
50.65454
51. 100-47-0
52. 9848-4
53. 100-44-7
54. 7440-41-7
55. 778747-5
56. 7787-49-7
57.13597-994
58. 123464
59. 84-74-2
60. 109-734
61. 107-924
62.543-904
63. 7789-424
64. 1010844-2
65. 7778-44-1
66. 52740-164
67. 75-2O-7
68. 13765-19-0
69. 592-014
70. 26264-08-2
71.7778-54-3
72.13346-2
73. 63-25-2
74. 156346-2
75. 75-154
76. 56-23-5
77. 57-74-9
78. 7782-504
79. 108-90-7
80. 6746-3
81.7790444
82.292148-2
83. 1066-304
84. 7738-944
85. 10101434
86. 10049454
87.544-18-3
88.14017414
89. 56-724
90. 1319-77-3
91.4170-3P-.T
Chemical Name
Cuoric Oxide
Cupric Sulfata
Cuproui Oxide
Ethylene
Hydrochloric Acid
Hydrogen Fluoride
Lied Oxide
Mercury
Methane
Napthalene
Nickel
Nitric Acid
Phosphorus
Chemical Name
Arsenic Tritulf idc
Barium Cyanide
Benzene
Benzoic Acid
•Benzonitrile
Benzoyl Chloride
Benzyl Chloride
Beryllium
Beryllium Chloride
Beryllium Fluoride
Beryllium Nitrate
Butyl Acetate
n-Butyl Phthalate
Buryiamina
Butyric Acid
Cadimium Acetate
Cadmium Bromide
Cadmium Chloride
Calcium Arunate
Calcium Arunite
Calcium Carbide
Calcium Chromate
Calcium Cyanide
Calcium Dodecylbenzene
Sulfonata
Calcium Hypochlorite
Cap tan
Carbaryl
Carbofuran
Carbon Disuifide
Carton Tetrachloride
Chlordana
Chlorine
Chlorobenzene
Chloroform
Chlorosulfonic Acid
Chlorpynfot
Chromic Acetate
Chromic Acid
Chromic Sulfate
Chromout Chloride
Cobaltout Formate
CobMtout Sulfamate
Coumao'"^
. CreaM
CrotonMdenyde
CAS Number
27. 7778-50-9
28. 1310-58-3
29. 11547-1
30. 1058841-9
31. 1310-73-2
32. 7646-784
33. 7772-994
34. 7664-93-9
35. 10848-3
36. 1330-20-7
37. 764645-7
38. 7733424
CAS Number
92. 142-71-2
93. 12002434
94. 7447-394
95.3251-234
96. 589346-3
97. 7758-98-7
98. 10380-29-7
99. 81542-7
100.506-774
101.11042-7
102.94-75-7
103.94-11-1
104.50-29-3
105.333414
106.191840-9
107. 1194454
108. 117404
109.25321-224
110. 266-38-19-7
111. 26952-234
112.8003-194
113.75-994
114.62-73-7
115.6047-1
116.10949-7
117. 12440-3
118.25154444
119.51-284
120.25321-144
121.8540-7
122.298444
123. 330-54-1
124.27176474
125. 115-29-7
126.72-204
127. 106494
128.563-12-2
129.100-414
130. 107-15-3
131.106-934
132. 10746-2
133.6040-4
134. 1185474
135.2944474
136.7705484
Chemical Nw
Potassium Dichi
Potassium Hyflr
Propyltne "
Sodium Oicnror
Sodium Hvdrox
Stannic Chlono.
Sunnout CRIon
Sulfuric Acid
Toluene
Xylene
Zinc Chloride
Zinc Sulfate
Chemical Nir
Cupric Acetate
Cupric Aeetoertenr
Cupric Chloride
Cupric Nitrate
Cupric Oxalate
Cupric Sulfate
Cupric Sulfate Amr
Cupric Tanrate
Cyanogen Chloride
Cyciohexane
2.4-0 Acid
2 .4-O Esten
DOT
Oiazinon
Oicamba
Oichlobenil
Oichlone
Oicnlorooenzen* u
Dichloroprooen* u
Oichloroprooene I;
Dichloroproptne-
Oicniorooropane
2-2-Oichioropropic
Oichlorvos
Dieldrm
Oiethylemine
Oimethylemine
Oinitrobenzene Id
Oinitropnenol
Oinitrotoluene (ill
Oiouat
Disulfoton
Diuron
Oodecylbenzeneu
Endotultin till IK
Endrin snd.M«tsc
EoicnioronvOrm
Ethion
Ethyl Binzent
Ethyl* nediimin*
Ethylen* Oibrom.
Ethylene Oiehion
EOT A
Perrtc Ammoniur
F«rrtc Ammoniur
Perrie ChlOfid*
C-8
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OSWER DIRECTIVE 9345.0-01
II. HAZARDOUS SUBSTANCES
CAS Number
137.7783-504
138. 10421-48-*
139.10028-224
140. 1004549-3
141.775844-3
142.7720-78-7
143.206-444
144.50-004
145.64-184
146.110-174
147.9841-1
148.86404
149. 76-444
150. 118-74-1
151.8748-3
152.67-72-1
153.70-30-4
154.77-47-4
155.7647414
156.7664-39-3
157.74-904
158. 778348-*
159.78-794
160.42504-46-1
161.115-32-2
162. 143-504
163.30144-2
164.3687-314
165. 7758-95-4
166.13814-964
167. 7783-46-2
168. 10101434
169. 18256-98-9
170. 7428-484
171. 1573940-7
172. 1314474
173.592474
174.5849-9
175. 14307-354
176. 121-75-6
177. 110-16-7
178.108-314
179.203245-7
180.59244-1
181. 10045-944
182.7783-35-9
183.592454
184. 10415-75-5
185. 72-43-5
186. 74-93-1
187. 80424
188. 298404
189. 7786-34-7
190.315-18-4
191. 7544-7
Chemical Name
Firric Fluoride
Ferric Nitrate
Ferric Suifate
Ferrous Ammonium Suifate
Ferrous Chloride
Ferrous Sulfata
Fluoranthene
Formaldehyde
Formic Acid
Fumaric Acid
Furfural
Guth'ion
Heptachlor
Hexachlorobenzane
Hexachlorobutadiene
Hexachloroe thane
Hexechlo'rophene
Hexachlorocyclopentadiene
Hydrochloric Acid
(Hydrogen Chloride)
Hydrofluoric Acid
(Hydrogen Fluoride)
Hydrogen Cyanide
Hydrogen Sulfide
Isoprene
Itopropanolamine
Dodecylbenzenesulfonate
Kel thane
Keoone
Ltad Acetate
Lead Arsenate
Lead Chloride
Lead Fluoborate
Ltad Fluoride
Ltad Iodide
Lead Nitrate
Lead S iterate
Lead Suifate
Lead Sulfide
Lead Thiocyanate
Lindane
Lithium Chromate
Mel th ion
Male* Add
Mateic Anhydride
Mercuric Cyanide
Mercuric Nitrate
Mercuric Suifate
Mercuric Thiocyenate
Mercuroui Nitrate
Methoxychior
Methyl Mercaptan
Methyl Methacryiate
Methyl Parathion
Mevinphos
Mexacarbate
Monoa thy lamina
CAS Number
192. 74494
193.300-764
194.91-20-3
195. 1338-244
196. 7440424
197. 15699-184
198.37211454
199. 12064-48-7
200. 14216-75-2
201.778641-4
202. 7697-37-2
203. 98-954
204. 10102-444
205. 25154-554
206. 1321-124
207. 3062549-4
208. 56-38-2
209. 606-93-5
210.87464
211.85414
212. 108-95-2
213.75-444
214. 7664-38-2
215. 7723-144
216. 1002547-3
217. 131440-3
218. 7719-12-2
219.7784-414
220. 10124-50-2
221.7778-50-9
222. 7789404
223. 772244-7
224. 2312-354
225. 7949-4
226. 123424
227. 1336-36-3
228. 151-504
229. 1310-58-3
230. 75-56-9
231. 121-29-9
232.91-22-5
233. 108-46-3
234.744648-4
235. 7761484
236. 763149-2
237. 7784-46-6
238. 1058841-9
239. 133343-1
240. 7631-90-5
241. 7775-11-3
242. 143-33-9
243.25155-304
244. 7681-494
245. 1672140-5
246. 1310-73-2
247. 7681-52-9
248. 124414
Chemical NMIM
Monomethy lam i n»
Naled
Naphthalene
Naphthenic Acid
Nickel
Nickel Ammonium Suifate
Nickel Chloride
Nickel Hydroxide
Nickel Nitrete
Nickel Sulfete
Nitric Acid
Nitrobenzene
Nitrogen Dioxide
Nitrophenol (ell isomert)
Nitro toluene
Peraformaldehyde
Parathion
Pentachlorobenzene
Pentachlorophenol
Phenanthrene
Phenol
Phosgene
Phosphoric Acid
Phoephoru*
Phosphorus Oxychloride
Phosphorus Pentasulfide
Phosphorus Trichloride
Potassium Arsenate
Potassium Arsenite
Potassium Bichromate
Potassium Chromata
Potassium Permanganate
Propargita
Propionic Acid
Propionic Anhydride
Polychlorinated Biphenylt
Potassium Cyanide
Potassium Hydroxide
Propylene Oxide
Pyrethrins
Quinoline
Retorcinol
Selenium Oxide
Silver Nitrate
Sodium Arsenate
Sodium Arsenite
Sodium Bichromate
Sodium Bifluoride
Sodium Bisulfite
Sodium Chromate
Sodium Cyanide
Sodium Oodecylberutne
Sulfonate
Sodium Fluoride
Sodium Hydrosulfide
Sodium Hydroxide
Sodium Hypochlorite
Sodium Methylata
CAS Number
249. 7632-004
260. 7558-79-4
251.7601-544
252. 10102-18-8
253. 7789-06-2
254.57-244
255.100-420-6
256.1277108-3
257. 7664434
258.93-764
259.200846-0
260.93-794
261.1356049-1
262.93-72-1
263. 3253446-6
264.72-544
265.95-94-3
266.127-18-4
267. 78-00-2
268.107-49-3
269. 7446-184
270. 10648-3
271.8001-35-2
272.12002-48-1
273.52484
274. 2532349-1
275. 79-014
276.2516742-2
277.27323-41-7
278.121-444
279. 75-50-3
280.541-09-3
281. 10102-06-4
282. 131442-1
283.27774-134
284. 108-05-4
285. 75-35-4
286. 1300-714
287.557-344
288.52628-254
289.1332-074
290. 7699-454
291.3486-354
292. 764645-7
293.557-21-1
294. 7783-49-3
295.557-414
296. 777946-4
297. 7779484
298.12742-2
299. 131444-7
300.16871-714
301.7733-024
13746494
16923-954
1464441-2
302.
303.
304.
305. 10026-114
Chemical N«m>
Sodium Nitrate
Sodium Phosphate. C
Sodium Phosphate. 1
Sodium Salenite
Strontium Chromata
Strychnine and Salti
Sty nine
Sulfur Monochloride
Su If uric Acid
2.45-T Acid
2.4,5-T Amines
2.45-T Esters
2.4.5-T Salts
2.4J5-TP Acid
2,4,5-TP Acid Erttn
TOE
Tetrachlorobenzent
Tetrachloroethane
Tttraethyl Lead
Tetraethyl Pyrophoc
Thallium (I) Sulfete
Toluene
Toxaphene
Trichlorobenzene (all
Trichlorton
Trichloroethene (all i
Tricnloroethylene
Triehloropheno! (all i
Triethenolemine
Dodecylbenzenesulf
Triethylamine
Trimethylamina
Uranyl Acetate
Uranyl Nitrate
Vanadium Pentoxidc
Vanedyl Suifate
Vinyl Acetate
Vinylidene Chlorid*
Xylenol
Zinc Acetate
Zinc Ammonium Chi
Zinc Berate
Zinc Bromide
Zinc Carbonate
Zinc Chloride
Zinc Cyanide
Zinc Fluoride
Zinc Formate
Zinc Hydrotulfite
Zinc Nitrate
Zinc Phtnoltulfonat
Zinc Phosphide
Zinc Silicofluonde
Zinc Suifate
Zirconium Nitrite
Zirconium Potamur
Zirconium Suifat*
Zirconium Tttracnic
C-9
-------
9345.0-01 OSWER DIRECTIVE
APPENDIX D: CRITERIA AND PROCEDURES FOR
HANDLING PA PETITIONS
-------
OSWER DIRECTIVE 9345.0-01
CRITERIA AND PROCEDURES FOR
HANDLING PA PETITIONS
A. Conditions a PA Petition Must Satisfy
To be complete, the petition must be written and contain
the following information:
(1) The petitioner's name, address, phone
number, and signature;
(2) A description of the location of the
release or threatened release,
including a marked map if possible; and
(3) How the petitioner is, or may be,
affected by the release or threatened
release.
The Region should not consider a petition complete or
initiate the 12-month period within which a PA must be conducted
or denied until all three of these basic kinds of information
are provided. If the Region receives an oral request to perform
a PA, the Region should instruct the petitioner to submit the
petition in writing and inform him or her of the information
required.
No particular wording is required for the petition, but a
sample petition format will be included in a public information
bulletin that is being prepared for Regions to provide to
interested persons. (A copy of the format sample is Attachment
A of this document.) The petitioner should provide sufficient
information to lead the Regional reviewer ("reviewer") to
suspect that there may be a release or threatened release of a
hazardous substance, pollutant, or contaminant. The petitioner
may be an individual person or any entity that comes within the
CERCLA section 101(21) definition of "person."
PA petitions may describe a release that requires remedial
or removal attention, or both. Petitioners should be
encouraged, therefore, to supply as much pertinent information
as possible to assist the reviewer in evaluating the petition
and to ensure that appropriate Agency attention is given to
releases or threatened releases that are the subject of the
petition. The following information, although not required to
be submitted, illustrates data that may accelerate a decision on
the petition:
(1) The type of substance(s) involved or a
D-l
-------
OSWER DIRECTIVE 9345.0-01
description of the -characteristics of
the substance(s);
(2) The nature and history of the
activities that have occurred regarding
the release or threatened release; and
(3) Whether State and local authorities
have been contacted about the release
or threatened release and what action
they have taken, if any.
When the release identified in a PA petition cannot be
addressed under CERCLA (CERCLA eligibility is described in
Section B, immediately below.), the release may warrant res
under other State or local authority. Regional reviewers
should, therefore, encourage petitioners to notify appropri
State and local agencies of the release. The public inform
bulletin also suggests that, before submitting petitions,
petitioners notify State and local agencies if they have no
already done so.
B. Factors for Determining the Appropriateness of a PA
The primary purpose of the petition process is to ider
and respond to releases and threatened releases that have r
yet come to EPA's attention. In evaluating petitions,
therefore, reviewers should be guided by their experience a
expert judgment in addition to the information provided in
petition. The time and resources required to perform a PA
should be weighed against'those required to deny a petitior
the impact of denial. Subsequent sections of this appendix
describe the methods, procedures, and criteria the lead age
will use in performing a remedial PA until proposed NCP
revisions are promulgated.
Upon receipt of a complete petition, the reviewer will
first determine if a PA of the release has already been
conducted. If no PA has been conducted, the Region should
employ the following criteria in determining whether a reqi
PA is appropriate: (1) whether the release or threatened
release is of a type that is within CERCLA authority; and i
whether sufficient information has been supplied to lead"tl
reviewer to suspect there may be a release or threatened
release.
CERCLA Eligibility. Certain CERCLA provisions deline;
circumstances in which approval of PA petitions is not
appropriate:
»
(1) CERCLA section 104(a)(3) generally prohibits res
to releases or threatened releases:
D-2
-------
OSWER DIRECTIVE 9345.0-01
(a) Of naturally occurring substances in their
unaltered form, or altered solely through
naturally occurring processes or phenomena, from
a location where it is naturally found;
(b) From products which are part of the structure of,
and result in exposure within, residential
buildings or business or community structures; or
(c) Into public or private drinking water systems due
to deterioration of the system through ordinary
use.
An exception to the general prohibition may be made if
the release or threatened release is a public health
or environmental emergency and no one else has the
authority or capability to respond in a timely
fashion.
(2) CERCLA definitions of hazardous substance, pollutant
or contaminant, in subsections 101(14) and 101(33),
respectively, exclude from these definitions
petroleum, including crude oil, natural gas, natural
gas liquids, liquefied natural gas, synthetic gas
usable for fuel, and mixtures of natural and synthetic
gas.
(3) CERCLA section 101(22) precludes response to releases
within the workplace which result in exposure to
persons with respect to which such persons may assert
a claim against their employer, certain engine exhaust
emissions, releases of nuclear material subject to the
Nuclear Regulatory Commission financial responsibility
requirements under section 107 of the Atomic Energy
Act of 1954, releases of source, byproduct, or special
nuclear material from a processing site under the
Uranium Mill Tailings Radiation Control Act of 1978,
and releases from the normal application of
fertilizer.
Sufficient Information. The petition should be denied if
the petitioner does not provide sufficient evidence to lead the
reviewer to suspect that there may be a release or threatened
release. (The kind of information that is needed to evaluate a
PA petition is identified in Section A. (p. D-l), above.)
Although this criterion will infrequently result in the denial
of a petition, it should be used to deny a petition that is
clearly frivolous. Before denying the petition for lack of
sufficient information, however, the reviewer should contact the
petitioner to ensure that all known, relevant facts are
considered. Petitioners do not have to supply detail that
D-3
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OSWER DIRECTIVE 9345.0-01
proves unambiguously that a release or threatened release
exists; at a minimum, the information must be of sufficient
detail to give the reviewer a reasonable basis for suspectinc
that a release or threatened release may exist. When
determining whether to deny a petition for lack of sufficient
information, the Region should balance the relative time
requirements of denying a petition against those required to
conduct a PA. In general, in evaluating the information and
resource requirements, Regions should err on the side of
approving PA petitions.
There are several kinds of petitions that are potentiall
difficult to deal with:
(1) A petition for multiple sites,
described generically, without
identification of releases or
threatened releases;
(2) A petition for a release or threatened
release where the effects or potential
effects on the petitioner (including
environmental effects) are highly
unlikely or non-existent; and
(3) A petition for a PA of an area-wide
problem with no identified source.
EPA cannot deny petitions within one of these three categorie:
but the Region can encourage petitioners to be as specific as
possible in defining what they believe to be a release and
providing as much information as possible about the source of
the release. The public information bulletin on PA petitions
will identify instances in which a petition would not be
appropriate and explain ways the public can more accurately
describe a release.
D-4
-------
OSWER DIRECTIVE 9345.0-01
C. Procedures for Handling Petitions
o Administrative Procedures
A PA petition must be submitted to the Regional
Administrator who has jurisdiction over the area where the
release or threatened release is located (a model letter
acknowledging the receipt of a petition is provided as
Attachment B). By statutory requirement, the Region must eithe
approve and complete the requested assessment or deny the
petition within 12 months of receiving a petition. The
statutory requirement establishes the outside limits for
completion of the PA or denial of the petition. Regions can, o
course, complete a PA or deny a petition in less time than the
statutory maximum. (A model approval letter is provided as
Attachment C). Since denial of a petition is also an official
Agency action, the denial must be sent by the appropriate
delegated Regional official. The petitioner should be notified
by letter that the petition is denied and given the basis for
denial using the criteria in Section B., p. D-2, above. (A mode
denial letter is provided as Attachment D.)
If a PA is performed in response to a petition, the Region
will send a copy of the completed PA report to the petitioner.
If the PA is conducted by a State via a cooperative agreement,
the State will make a recommendation upon which the Region will
base its decision about whether future actions are required.
The cover letter will include a description of any future
actions at the site. (A model cover letter is provided as
Attachment E.) All petitions, logs of follow-up telephone
contacts, follow-up letters, cover letters, and decision
documents, such as the PA report, must be retained in a file,
and the petition process must be tracked using the CERCLA
Information System (CERCLIS), as discussed below. (Attachment
provides instructions for tracking the petition process through
CERCLIS.)
o Insufficient Information
In instances where information is insufficient to lead the
reviewer to suspect that there may be a release or threatened
release, the reviewer may, based on his or her knowledge and
experience, make further inquiry. In such instances, the
reviewer should contact the petitioner to determine if
additional information can be supplied. Records of follow-up
phone calls or letters should be included in the PA file.
D-5
-------
OSWER DIRECTIVE 9345.0-01
o ATSDR Coordination
When a PA petition is received, the Agency for Toxic
Substance and Disease Registry (ATSDR) has requested that the „
Region provide a copy to.the appropriate ATSDR contact. ATSDR,
in their guidance for handling health assessment petitions, will
specify that the ATSDR contact provide Regional CERCLA program
offices with copies. If both agencies receive petitions for the
same site; they can coordinate their responses. (A list of
ATSDR Regional contacts is provided as Attachment F.)
o Federal Facilities
Under Executive Orders 11735 and 12580, certain functions
and responsibilities under the Clean Water Act and CERCLA,
respectively, are delegated to Federal agencies, including
responsibility for responding to PA petitions regarding releases
from their facilities. Accordingly, EPA will not perform PAs at
Federal facilities. The public information bulletin on PA
petitions will direct petitioners to address petitions regarding
releases from Federal facilities to the appropriate Federal
agency. If the Region receives a petition that involves a
release or threatened release at a Federal facility, the Region
will transfer the petition to the Federal Agency responsible for
the facility for evaluation and disposition. (A list of
Federal facility coordinators from whom Federal agency addresses
can be obtained is provided as Attachment G.)
o RCRA Facilities
Regions will respond to most petitions concerning RCRA
facilities. If the petition concerns an active RCRA land
disposal facility, the Region should check to see if a RCRA
facility assessment (RFA) of the site has been done. If an RFA
has been done, it will be considered the equivalent of a PA. If
an RFA is underway or scheduled within one year of the PA
petition, a CERCLA pre-remedial PA need not be done at the
facility. If an RFA will not be done within one year, the
Region will conduct a PA at the facility.
A generator, however, unless it was formerly a treatment,
storage, or disposal facility, is not subject to corrective
action or to corrective action for solid waste management units-
at the generator's facility. Consequently, PA petitions related
to generators' activities will almost always require CERCLA
response.
D-6
-------
OSWER DIRECTIVE 9345.0-01
o CERCLIS Tracking
CERCLIS will be used to track the receipt of PA petitions
and their disposition. CERCLIS uses generic data elements
called events to track the PA/SI process. PA is the generic
event code for PAs and related data. Regions will use the
numerical PA sub-event code, the next data level beneath the PA
event code, to enter data about PA petitions. When a PA
petition is received, the Region will enter the PA petition
sub-event code and the date of receipt. If the petition is
approved, the date of approval of the PA will be entered. If
the petition is denied, the Region will enter the sub-event code
for denial and the date of denial. (More detailed instructions
are provided in Attachment H.)
V. Supporting Materials
The following supporting materials are attached:
o Attachment A: Public petition format sample;
o Attachment B: Model letter of acknowledgement;
o Attachment C: Model approval letter;
o Attachment D: Model denial letter;
o Attachment E: Model cover letter;
o Attachment F: List of ATSDR Regional contacts;
o Attachment G: List of Federal facility
coordinators; and
o Attachment H: CERCLIS instructions.
D-7
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OSWER DIRECTIVE 9345.0-01
Attachment A. Sample Public Petitior
(Regional Administrator
United States Environmental Protection Agency
Region (insert proper Region number)(or) Federal Agency)
(address)
PRELIMINARY ASSESSMENT PETITION
[Instructions in brackets can be replaced with relevant
information, and the brackets deleted.]
Under the authority of CERCLA section 105(d), as amended,
the petitioner,
(Name):
(Address):.
(Telephone Number):.
hereby requests that Region [(insert number of U.S. EPA Region
in which release/threatened release is located from list
provided in the bulletin) of the United States Environmental
Protection Agency (or) (name of appropriate Federal agency, in
the case of a suspected release/potential release from a Feder;
facility)] conduct a preliminary assessment of the suspected
[release (or) threatened release] of a hazardous substance,
pollutant, or contaminant at the following location:
(Precise description of the
location of the release/threatened release;
attach marked map if possible)
Petitioner is affected by the [release (or) threatened release
because
« k
(Describe as completely as possible how you are
affected, or potentially affected, by the release/
threatened release) !_-
D-8
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OSWER DIRECTIVE 9345.0-01
* SAMPLE FORMAT _ *
(continued)
[The information requested below is not required but, to the
extent that it can be included, it will expedite review of and
response to your petition.]
Type or characteristics of the substance(s) involved:
Nature and history of any activities that have
occurred regarding the release/ threatened release:
State and local authorities you have contacted about
the release/threatened release and the response, if
any:
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OSWER DIRECTIVE 9345.0-01
Attachment B. Model Letter of Acknowledgement
(Insert date)
Name and address of petition
Dear (insert name of petitioner):
This letter is to notify you that the United States
Environmental Protection Agency Region (insert EPA Region
number) received your petition for a preliminary assessment of
fidentify the site that is the subject of the petition) on
(insert date petition was received). In accordance with secti
105(d) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980, as amended,
your petition will be evaluated to determine whether or not a
preliminary assessment of the site is appropriate. When a
determination is made, you will be informed of the approval or
denial of your petition. If a preliminary assessment is
determined to be appropriate, it will be completed within 12
months of the receipt of your petition.
If you have any questions about the preliminary assessmen
petition process, please contact (insert name and address of
Regional contact person) at (insert phone number).
Thank you for your interest and involvement in the
Superfund program.
(Delegated Regional Official)
U.S. Environmental Protection Agency
Region (insert EPA Region Number)
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OSWER DIRECTIVE 9345.0-01
Attachment C. Model Approval Letter
(Insert date)
Name and address of petitioner
Dear (insert name of petitioner):
This letter is to notify you that the United States
Environmental Protection Agency Region (insert EPA Region
number) has evaluated your petition for a preliminary assessment
of (identify the site that is the subject of the petition) and
has determined that a preliminary assessment of the site is
appropriate. Accordingly, a preliminary assessment of the site
will be completed by (insert date 12 months after the date of
the petition). When a report of the preliminary assessment is
completed, a copy will be forwarded to you.
If you have any questions about the preliminary assessment
process, please contact (insert name and address of Regional
contact person) at (insert phone number).
Thank you for your interest and involvement in the
Superfund program.
(Delegated Regional Official)
U.S. Environmental Protection Agency
Region (insert EPA Region Number)
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OSWER DIRECTIVE 9345.0-01
Attachment D. Model-Denial Letter
(Insert date!
Name and address of petitioner
Dear (insert name of petitioner):
This letter is issued in accordance with section 105(d) of
the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) of 1980, as amended, to notify you that
the United States Environmental Protection Agency Region (insert
EPA Region number) has evaluated your petition for a preliminary
assessment of (identify the site involved in the petition! and
has determined that a preliminary assessment of the site is not
appropriate. The determination was made because (describe
reason(s) for denying petition, e.g.. EPA is precluded bv the
definitions of hazardous substances and contaminants or
pollutants in subsections 101(14) and 101(33). respectively, of
the Comprehensive Environmental Response. Compensation, and
Liability Act(CERCLA). as amended, from responding to petroleum
releases).
If you have any questions about the denial of your
petition, please contact (insert name and address of Regional
contact person) at (insert phone number).
Thank you for your interest and involvement in the
Superfund program.
(Delegated Regional Official)
U.S. Environmental Protection Agency
Region (insert EPA Region Number)
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OSWER DIRECTIVE 9345.0-01
Attachment E. Model PA Report Cover Letter
/Insert date)
Name and address of petitioner
Dear (insert name of petitioner)
This letter transmits a copy of the report of the
preliminary assessment conducted in response to your petition,
which was received by U.S. EPA Region (insert appropriate Region
number) on (insert date of receipt of complete petition).
[Use either (1), (2) or (3), as appropriate.] [(l) The
results in the attached report indicate a release [(or) a
threatened release] of (insert namefs) of hazardous substance(s)
or pollutant(s) or contaminantfs)) at the described site.
Accordingly, evaluation of the site in the pre-remedial program
of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), as amended, will continue, and a Site
Investigation (SI) will be conducted at the identified location.
Data collected during the SI will be used to determine whether
subsequent actions at the site are necessary and, if so, the
priority for any such actions. Remedial action will be
undertaken at the site in accordance with its assigned priority;
or (2) The results in the attached report indicate that no
further pre-remedial action under CERCLA is warranted at this
time because (insert the reason no further CERCLA pre-remedial
action is appropriate, e.g.. the site never handled hazardous
substances or pollutants or contaminants.) or (3) the results of
the attached report indicate that removal action may be required
at the described site. Accordingly, the site has been referred
to the removal action program for evaluation.]
If you have any questions about the preliminary assessment
report [or further action at the site], please contact (insert
name and address of Regional contact person) at (insert phone
Thank you once again for your interest and involvement in
the Superfund program.
(Delegated Regional Official)
U.S. Environmental Protection Age
Region (insert EPA Region Number)
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OSWER DIRECTIVE 9345.0-01
Attachment F. ATSDR REGIONAL CONTACTS
Marilyn R. Disirio
Louise A. House
EPA Region I
Room 1903
John F. Kennedy Building
Boston, MA 02203
FTS: 835-3667
Async: 329-1103 (Disirio)
Comm: (214) 655-6725
Async: 329-1103 (DeSirio)
William Q. Nelson
Denise Johnson
EPA Region II, Room 737
26 Federal Plaza
New York, NY 10007
FTS: 264-8672
Comm: (212) 264-8672
Edison: FTS: 340-6657
Comm: (201) 321-6657
Async: 329-1109 (Nelson)
Async: 329-1127 (Johnson)
Charles J. Walters
M. Joyce McCurdy
EPA Superfund Office
EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
FTS: 597-7291 (Walters)
FTS: 597-3154 (McCurdy)
Comm: (214) 597-7291 or 3154
Async: 329-1112 (Walters)
Async: 329-1125 (McCurdy)
Casimer V. Pietrosewicz
S. Cody Jackson
Air & Waste Management Oivis:
EPA Superfund Office
EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
FTS: 257-3931 (Pietrosewicz;
FTS: 257-2643 (Jackson)
Comm: (404) 347-3931 or 264:
Async: 329-1110 (Pietrosewic
Async: 329-1124 (Jackson)
Louise A. Fabinski
Denise Jordan-Izaguirre
Emergency & Remedial Branch
EPA Region V
230 S. Dearborn
Chicago, IL 60604
FTS: 886-0398 (Fabinski)
FTS: 886-3428 (Jordan-Izagu
Comm: (312) 886-0398 or 342
Async: 329-1104 (Fabinski)
Async: 329-1126 (Jordan-Izagi
Carl R. Hickam
George L. Pettigrew
EPA Region VI
Office for Health Response
Allied Bank Tower at Fountai
Plaza
1445 Ross Avenue
Dallas, TX 75202
Comm: (517) 565-3667
FTS: 255-6725
Async: 329-1106 (Hickam)
Async: 329-1128 (Pettigrew)
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OSWER DIRECTIVE 9345.0-01
Edward J. Skowronski
David A. Parker
Waste Management Branch
EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
FTS: 757-2856
Async: 329-1111 (Skowronski)
-Donald W. Hawkins
Ralph McDuffie
Toxics & Waste Management
Division
EPA Region IX
215 Freemont Street
San Franciso, CA 94105
FTS: 454-7742
Comm: (415) 974-7742
Comm: (415) 974-7742
Async: 329-1105 (Hawkins)
Michael A. McGeehin
Tamera Kicera
Waste Management Division
EPA Region VIII, Suite 1300
999 18th Street
Denver, CO 80202
FTS: 564-1526 (McGeehin)
FTS: 564-1837 (Kicera)
Comm: (303) 293-1526 or 1837
Async: 329-1107 (McGeehin)
Joel D. Mulder
Greg Thomas
EPA Region X (M/S 525)
1200 6th Avenue
Seattle, WA 98101
FTS: 399-2711
Comm: (206) 442-2711
Async: 329-1108
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OSWER DIRECTIVE 9345.0-01
Attachment G. Regional Federal Facility Coordinators
Region I
Clara Chow
FTS 835-3287
Region II
Bob Hargrove
FTS 264-5390
Region III
Fran Mulhern
FTS 597-1168
Region IV
Art Linton
FTS 257-3776
Region V
Kestutis Ambutas
FTS 353-1394
Region VI
Jim Highland
FTS 255-2260
Region VII
Glen Yager
FTS 757-2823
Region VIII
Elmer Chenault
FTS 564-1644
Region IX
Laura Fujii
FTS 454-7539
Region X
Clark Smith
FTS 399-1327
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OSWER DIRECTIVE 9345.0-01
Attachment H. CERCLIS Instructions
CERCLIS will track PA petitions and their disposition as
sub-events of the preliminary assessment event, 2101 sub 004
Preliminary Assessment (PA).
(1) When a PA petition is received, the sub-event
3101 sub 003 should be entered along with the
date of receipt.
(2) If the petition is approved, the sub-event 3103
sub 003 should be entered along with the date
of the approval of the PA.
(3) If the petition is denied, the sub-event 3103
sub 004 should be entered along with the date
of denial.
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OSWER DIRECTIVE 9345.0-01
APPENDIX E:
CRITERIA FOR REMOVAL RESPONSE
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OSWER DIRECTIVE 9345.0-01
CRITERIA FOR REMOVAL RESPONSE
The following factors shall be considered in determining
the appropriateness of a removal action:
(1) Actual or potential exposure to hazardous substances
or pollutants or contaminants by nearby populations,
animals, or food chain;
(2) Actual or potential contamination of drinking water
supplies or sensitive ecosystems;
(3) Hazardous substances or pollutants or contaminants
in drums, barrels, tanks, or other bulk storage
containers, that may pose a threat of release;
(4) High levels of hazardous substances or pollutants or
contaminants in soils largely at or near the
surface, that may migrate;
(5) Weather conditions that may cause hazardous
substances or pollutants or contaminants to migrate
or be released;
(6) Threat of fire or explosion;
(7) The availability of other appropriate Federal or
State response mechanisms to respond to the release;
(8) Other situations or factors which may pose threats
to public health or welfare or the environment.
E-l
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